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growing up, petitioner occasionally assisted his father on the
coffee bean and citron plantation.
Shortly after his entry into medical practice, petitioner
began to attend various business and financial seminars in order
to become more educated about efficiently sustaining a private
medical practice. During one of these seminars in 1982,
petitioner met Thomas Moore (Mr. Moore), a financial adviser with
Coordinated Financial Services (CFS) of Salt Lake City, Utah.
Mr. Moore was a promoter for Blythe I.
Petitioner engaged Mr. Moore to conduct a comprehensive
analysis of petitioner's personal and business financial
situation. One of Mr. Moore's recommendations was to "invest in
a tax-sheltered program designed to generate $55,000 of
deductions in 1982", and thus he introduced petitioner to the
Blythe I offering, which was being promoted as an agricultural
research and development partnership. According to petitioner,
Mr. Moore had no apparent previous experience with agricultural
or research and development partnerships.
Mr. Moore 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 I. Petitioner reviewed the document and then passed along
2 The private placement memorandum consisted of some 47
pages, plus eight exhibits, and a table of contents.
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