Jackie H. Hunt - Page 6




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          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.                                                                 





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