-5- letter that was attached to the memorandum, informed a potential investor that the Internal Revenue Service (IRS) had been conducting a “tax shelter program” to identify and examine “abusive” tax shelters and that such a program “increases the likelihood that the Partnership’s and a Partner’s return may be audited.” The private placement memorandum also informed the reader that the depreciation deductions and investment tax credit that the partnership intended to claim and pass through to its partners would be based on a fair market value of each master video disk of $877,663, and that there was no assurance “that the Masters could be sold for the appraised value or that the lease fee program will provide the Partnership with a fair return on equity.” Petitioner discussed the possibility of purchasing an interest in the partnership with Freasier. Petitioner knew that acquiring an interest in the partnership would provide him with immediate and future tax advantages. In particular, he understood that he would receive tax benefits of up to $3.80 for each $1 invested. After petitioner became a limited partner in the partnership, the partnership’s tax return was audited by the IRS. As a result of this audit, on February 27, 1987, the IRS sent petitioners, and other partners in the partnership, a notice of final partnership administrative adjustment (FPAA) for 1982 and 1983. The partnership's tax matters partner thereafter filed a petition in this Court to contest the adjustments contained in the FPAA.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011