3
partner involved with the promotion of the Barrister
partnerships. In response to his inquiries, petitioner received
another brochure that apparently addressed his remaining
questions about the Barrister partnerships.
The record includes private placement memoranda for Series
98 and Series 124, and the offering summary for Barrister
Equipment Associates Series 115 (Series 115). The parties have
stipulated that the offering summary for Series 115 is
essentially the same as the offering summaries for Series 98 and
Series 124. According to the various materials, the partnerships
were organized to lease literary properties for publication,
distribution, and sale.
The private placement memoranda stated that the offerings
were exempt from registration with the Securities and Exchange
Commission. In addition, both warned that investment in the
securities offered involved a high degree of risk and should not
be purchased by anyone who could not afford the loss of their
entire investment.
The offering summary included a chart identified as a
"Typical Illustration of Anticipated Federal Tax Aspects For a
Full Unit Investor". For a taxpayer in the 50-percent tax
bracket, a full unit investment was projected to yield a tax
savings of 4 times the amount of cash invested in the first year
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