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the offering to his certified public accountant and tax attorney,
Denis McDevitt (Mr. McDevitt), whom petitioner had recently hired
to prepare his income tax returns. After reviewing the offering,
Mr. McDevitt advised petitioner that he had no problem with
petitioner's investment in Blythe I. Petitioner did not consult
any independent expert in the area of agriculture or jojoba
plants as to whether jojoba oil or any other jojoba derivative
had a potentially lucrative commercial market. Petitioner,
nevertheless, invested in Blythe I.
On his joint 1982 Federal income tax return, petitioner
reported wages of $84,702 from his medical practice and other
employment, as well as $14,336 from his wife's employment.
Petitioner also reported interest income of $579, taxable
dividend income of $118, a State income tax refund of $1,491, a
capital loss of $2,000, and taxable pension income of $25,633.
Additionally, petitioner reported a loss of $20,925 from Blythe
I. Thus, petitioner reported total income of $103,934 and a
total tax liability of $24,211.
On his joint 1983 Federal income tax return, petitioner
reported wages of $37,239 from his medical practice and other
employment, as well as $15,042 from his wife's employment.
Petitioner also reported interest income of $610, a State income
tax refund of $274, and taxable pension income of $26,851.
Additionally, petitioner reported a loss of $981 from Blythe I.
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