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interest, one payable on February 3, 1986, and the other on
February 2, 1987.
As a condition of becoming a limited partner, the
partnership required an investor to assume recourse debt of
$114,805 per partnership unit purchased, which represented his or
her proportionate share of the note executed by the partnership
in connection with the purchase of the additional equipment. The
partnership anticipated that the obligation assumed by the
limited partners pertained to the last installments of the
partnership note, due between January 1, 1990, and January 1,
1992.
The POM included the following projection of tax benefits
per partnership unit for the first years of the transaction:
50 Unit Minimum 100 Unit Maximum
Projected Loss as a Percent ProjectedLoss as a Percent
Year InvestmentTax Loss of Investment Tax Loss of Investment
1985 $8,500 $30,170 355 $30,173 355
1986 115,750 47,223300 47,378 301
1987 115,750 45,247287 45,539 289
1988 -0- 18,437 18,868
1989 -0- 13,728 12,847
Total 40,000 154,805 387 154,805 387
1 Does not include interest at 12 percent per annum.
Petitioner's4 Decision to Invest
On or about November 21, 1985, petitioner executed
subscription documents to purchase one unit in the partnership,
4 References to petitioner in the singular refer to Douglas
A. Vander Heide.
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