Dennis E. Pewitt and Kathleen M. Pewitt - Page 5

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          and told him that if the Pewitts wished to make such an investment,         
          they should jointly meet with him.                                          
               At the second meeting, Mr. Colwill discussed with Mr. and Mrs.         
          Pewitt the risks and rewards of an investment in Media Marketers,           
          including tax ramifications.  Mr. Colwill gave the Pewitts a                
          prospectus; both Mr. and Mrs. Pewitt "looked" at the prospectus but         
          did not understand its content.  As Mr. Pewitt testified:  "It was          
          way over our heads at that point."                                          
               Mr. and Mrs. Pewitt jointly became limited partners of Media           
          Marketers in 1983 and partners of Assured Communications in 1984.           
          (Although the record is scant with respect to Assured                       
          Communications, it appears that petitioners' investment in that             
          partnership was made through Mr. Colwill, who followed the same             
          procedures with regard to Mr. and Mrs. Pewitts' investment in               
          Assured Communications as he had done with their investment in              
          Media Marketers.)                                                           
               Mrs. Pewitt signed the initial investment documents relating           
          to both Media Marketers and Assured Communications.  She was listed         
          on the Forms K-1 issued by the partnerships as a partner.                   
          Subsequent to petitioners' divorce in 1987, and prior to the filing         
          of the petition in this case, she wrote Mr. Colwill requesting              
          then-current information about Media Marketers and Assured                  
          Communications.                                                             







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