Bevel M. and Patricia N. Hoffpauir - Page 4

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               Petitioner wife attended a seminar with about 30 people held           
          at ITC around August 1983.  Petitioner attended a seminar at ITC            
          a couple of weeks later which was attended by 10 or 15 people.              
          Petitioners later met one-on-one with Dollar and received Century           
          promotional materials.  Petitioners believed that Century's                 
          promotional materials looked very professional, that Dollar made            
          credible presentations, and that Century was founded by well-               
          known people with appropriate expertise.  Petitioners did not               
          investigate Century's founders.  The Century program was marketed           
          as a "tax advantaged equipment lease".                                      
               Petitioner wife saw Century accounting software demonstrated           
          at Dollar's office.  Petitioner was out of town at that time and            
          did not see it demonstrated.  Petitioners did not have their own            
          copy of the software.  Petitioners believed there was a good                
          marketing plan for the accounting software.                                 
               Petitioners saw literature from Century that stated, and               
          they believed, that home use of computers and software would grow           
          tremendously in the coming years.                                           
               Petitioner's accounting program was in a cassette format.              
          Petitioner believed that a cassette format was suitable for home            
          and small business use, but that it would not be adequate for a             
          business the size of SDSI, which used a hard disk format.                   
               On November 2, 1983, petitioners leased an interest in                 
          accounting software entitled "Accounting Control System; Accounts           





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