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SLA filed a petition for the 1983 taxable year with this
Court in docket No. 27185-91, on November 22, 1991. In the
petition SLA stated that “The Film was placed in service by the
Partnership during July 1982 at which time it was released in
more than 125 motion picture theaters.” There is no evidence in
this record that contradicts that statement.
D. Petitioners’ Interest in SLA
Petitioner, Lester L. Samford, issued a check to SLA for
$13,836 on November 29, 1982. Petitioners held a 1.96000 percent
interest in SLA. The following documents relating to SLA were
signed by petitioners: Purchaser Questionnaire, Subscription
Agreement with an attached Annex I dealing with Powers of
Attorneys-in-Fact, a Negotiable Promissory Note, a Security
Agreement, an Assumption Agreement, and an Alternate Negotiable
Promissory Note. The power of attorney provided that the general
partners had the power and authority to act for petitioners in
the filing of documents required to be filed. All of the above
documents were dated and notarized July 22, 1982. Even though
these documents were notarized, petitioners claim, and respondent
does not dispute, that these documents were actually executed
after September 3, 1982.
E. Transactions After September 3, 1982
In the State of Washington, William Bratton and Stephen
Roberts (Bratton and Roberts), certified public accountants,
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