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CONCERNING ANY ASPECT OF THE INVESTMENT DESCRIBED
HEREIN. EACH INVESTOR MAY OBTAIN ANY ADDITIONAL
INFORMATION NECESSARY TO VERIFY THE ACCURACY OF THE
INFORMATION CONTAINED IN THIS MEMORANDUM TO THE EXTENT
THAT THE GENERAL PARTNER POSSESSES SUCH INFORMATION OR
CAN ACQUIRE IT WITHOUT UNREASONABLE EFFORT OR EXPENSE.
* * * * * * *
NO REPRESENTATIONS OR WARRANTIES OF ANY KIND ARE
INTENDED OR SHOULD BE INFERRED WITH RESPECT TO THE
ECONOMIC RETURN OR TAX ADVANTAGES WHICH MAY ACCRUE TO
THE INVESTORS IN THE UNITS.
EACH PURCHASER OF UNITS HEREIN SHOULD AND IS
EXPECTED TO CONSULT WITH HIS OWN TAX ADVISOR AS TO THE
TAX ASPECTS.
In addition to the general warnings, the PPM described the risk
factors with respect to the projected Federal income tax
consequences of an investment in Jojoba as follows:
The General Partner anticipates that a substantial
portion of the capital contributions of the Limited
Partners to the Partnership will be used for research
and experimental expenditures of the type generally
covered by Section 174 of the Code. However,
prospective investors should be aware that there is
little published authority dealing with the specific
types of expenditures which will qualify as research or
experimental expenditures within the meaning of Section
174, and most of the expenditures contemplated by the
Partnership have not been the subject of any prior
cases or administrative determinations.
* * * * * * *
No ruling by the Service has been or will be sought
regarding deductibility of the proposed expenditures
under Section 174 of the Code.
The PPM referred prospective investors to a November 8,
1992, tax opinion letter prepared by the law firm of Caplan &
Resnick and addressed to Jojoba’s general partner (Caplan
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