Lawrence R. Roberson - Page 6

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          Southampton investment was that "If they would do everything                
          that they said in the booklet, it looked okay to him."                      
               Based on his discussions with Cunningham and Parnell, and              
          on his own research of the music industry, petitioner decided to            
          invest in Southampton and signed a master recording lease                   
          agreement on December 22, 1982.  Petitioner was aware of the tax            
          benefits expected from the investment.  The availability of                 
          those benefits for the 1982 taxable year had an impact on                   
          petitioner's decision to sign the lease agreement prior to the              
          end of the year.  Pursuant to the agreement, petitioner was to              
          pay Southampton a total of $10,5003 for a one-fourth leasehold              
          interest in a master recording featuring Ray Pillow, a country-             
          western singer.  The lease was for a term of 5 years and 10                 
          months.  Petitioner had not listened to or received a copy of               
          the Ray Pillow master recording prior to investing in                       
          Southampton.                                                                
               Petitioner's master recording was to be distributed as a               
          phonograph album by Indigo Music Co. (Indigo), a distributor                
          recommended to petitioner by Southampton.  Petitioner did not               
          meet or negotiate with anyone from Indigo prior to investing in             
          Southampton.  Pursuant to his agreements with Indigo and                    

          3  Petitioner paid $8,400 on or about the date the lease was                
          signed and reported that amount as rental expense on his 1982 tax           
          return.  The remaining $2,100 was paid approximately 1 year                 
          thereafter and reported as rental expense on petitioner's 1983              
          return.                                                                     




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