Dolores J. Myers - Page 9




                                        - 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.                            





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