- 8 - * * * * * * * (h) He has carefully reviewed and understands the various risks of an investment in the Partnership, including the risks summarized in the Private Placement Memorandum under “The Risks Factors” and described in greater detail elsewhere in the Memorandum; * * * * * * * * * * (j) He understands that an investment in the Partnership is speculative and involves a high degree of risk, [and that] there is no assurance as to the tax treatment of items of Partnership income, gain, loss, [or] deductions of credit * * * The Myerses paid for their seven units in Jojoba by check for $7,000 and by issuing the jointly signed promissory note for the balance, $12,950. Mr. Matsuda received a commission on the sale of the Jojoba units to the Myerses. Audit of Jojoba and Settlement Offers In November 1988, respondent sent to Mr. Matsuda, Jojoba’s tax matters partner (TMP), and to petitioners and other limited partners notices of final partnership administrative adjustment (FPAA) for the partnership taxable years 1982 through 1986.4 In July or August of 1991, some limited partners settled with respondent regarding the taxable years covered by the FPAAs. 4The record includes notices of final partnership administrative adjustment (FPAA) only for the partnership taxable years 1982, 1983, 1985, and 1986, the taxable years before us. The FPAAs for 1982 and 1983, however, indicate that the partnership taxable year 1984 was also adjusted.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011