- 3 - During 1982, Mr. Sheets approached petitioner about investing in Blythe II, which was being promoted as an agricultural research and development partnership. Blythe II was the first agricultural type investment opportunity that had been proposed by Mr. Sheets for consideration by petitioner. Mr. Sheets provided petitioner with a fairly voluminous private placement memorandum2 (the offering), which described the proposed investment in and the activities to be conducted through Blythe II. Petitioner reviewed the document and then passed along the offering to his certified public accountant, Clarence Hulse (Mr. Hulse), who routinely reviewed petitioner's other investment opportunities. After perusing the offering, Mr. Hulse advised petitioner that the "risk reward" appeared to justify an investment in Blythe II. Petitioner did not consult an attorney or any independent expert in the area of agriculture or jojoba plants regarding whether jojoba oil or any other jojoba derivative had a potentially lucrative commercial market. Petitioners, nevertheless, invested in Blythe II. On their joint 1982 Federal income tax return, petitioners reported wages of $506,767.52 from petitioner's medical practice, interest income of $46,572.78, taxable dividend income of $712.30, capital gains of $56,589.02, and other income of 2 The private placement memorandum consisted of some 47 pages, plus eight exhibits, and a table of contents.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011