- 6 - statement that the investor had been advised to consult with an attorney concerning the tax consequences of the investment. Petitioner purchased two interests in Yuma Mesa in December 1982. At the time she purchased the interests, she knew of the sizeable tax benefits that the promoters projected the partners would receive for taxable year 1982. Petitioner was issued a Schedule K-1 by the partnership which reflected a $23,174 ordinary loss for taxable year 1982. At this time, petitioner had just recently contributed only $7,142 in cash to the partnership.3 As a limited partner, petitioner did not participate in the activities of the partnership. She did not hear of Yuma Mesa until several years later, when she was contacted by other limited partners who were concerned that they were being treated unfairly by the general partners and that their investments might have been diverted into another partnership. On petitioner’s Federal income tax return for taxable year 1982, she reported $121,000 in compensation from her professional association, and $2,421.61 in other income. From this she subtracted a $23,254.99 loss as reported on Schedule E. On the 3Petitioner testified that she was uncertain of the amount of cash she contributed in 1982. Because nothing else in the record indicates petitioner’s investment varied from that which was stated in the private placement memorandum, we accept this document’s stated terms as accurately reflecting petitioner’s investment.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011