Bevel M. and Patricia N. Hoffpauir - Page 5

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          Receivable" from Century.  Petitioners paid $4,850 for their                
          interest in the software.  They paid $2,975 on November 2, 1983,            
          and $1,875 on April 30, 1984.  Petitioners invested in the                  
          accounting software through a purported joint venture with three            
          other parties whom they never met.  Petitioners' one-fourth                 
          interest in the software (for which they paid $4,850) was valued            
          by Century at $93,750 (one-fourth of $375,000).  Petitioners did            
          not arrange for an independent appraisal of the software.                   
          Petitioners signed an agreement provided to them by Dollar under            
          which they hired ALA Enterprises (ALA) on November 25, 1983, to             
          distribute the software.  The distribution agreement said ALA               
          would sell 500 copies of the accounting software package for the            
          fee petitioners paid ALA.  Petitioners never estimated how many             
          copies of the accounting software package would have to be sold             
          to make a profit.                                                           
               Petitioners invested in accounting software instead of video           
          game software because petitioner heard from Alan Stone with Far             
          East Video, a client of SDSI which had exclusive distribution               
          rights in the United States from Nintendo for the Space Fever and           
          Sheriff video games, that the video game market was soft in 1983.           
               Petitioners did not talk to a tax or financial adviser                 
          (other than Dollar) before they invested in the accounting                  
          software.                                                                   







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