S. Byrne Doyle and Barbara S. Doyle - Page 17

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          Jonell did not carry out the other part of his authority under              
          the power of attorney by executing the partnership agreement on             
          behalf of Mr. Doyle.  Additionally, we note that Mr. Doyle later            
          consented in a signed writing that Mr. Farley act as general                
          partner after Mr. Jonell had resigned.  This would indicate that            
          some agreement in respect of the operations of the partnership              
          existed and that, absent any contrary evidence, the agreement               
          attached to the private placement memorandum represented that               
          understanding.                                                              
               Furthermore, petitioners have not offered any evidence to              
          indicate that there is a different agreement from the one in the            
          record which governs the partnership of which Mr. Doyle was a               
          member, nor that the partnership agreement in the record pertains           
          to a different partnership.  Petitioners concede that Mr. Doyle             
          was a partner, and it is established that the 29 partners                   
          involved invested $425,000 in the partnership.  Under these                 
          circumstances, we think it highly unlikely that there was not an            
          executed partnership agreement.                                             
               However, we find it unnecessary to find as a fact that the             
          partnership agreement attached to the private placement                     
          memorandum was executed.  We simply hold that petitioners have              
          failed to carry their burden of proof that it was not executed.             
          In this context and having in mind the difference in the location           
          of the burden of proof in this case as contrasted with the                  






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