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* * * * * * *
(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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