Joseph P. and Mary B. McDonald - Page 5




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          investment, petitioners relied solely upon Mr. Trimboli’s advice,           
          they consulted no one else, and they made no independent                    
          investigation or inquiry into its legitimacy.                               
               Mr. Trimboli had been working at a public accounting firm              
          since 1976.  In 1983, Mr. Trimboli left the firm in order to                
          start his own business along with one partner, Gerard Cannito, in           
          which he began offering services as a financial planner as well             
          as a certified public accountant.  Prior to leaving the firm, Mr.           
          Trimboli had no experience as a financial planner.  By the end of           
          1983, in addition to having earned a bachelor’s degree in                   
          accounting, Mr. Trimboli was in the process of completing courses           
          required to become a certified financial planner through the                
          College of Financial Planning.                                              
               Mr. Trimboli learned of jojoba investments in early 1983.              
          In June 1983 and again in September 1983, Mr. Trimboli traveled             
          to California to investigate the partnership as a potential                 
          investment opportunity.  He traveled to Blythe, California, and             
          to Bakersfield, California, where there were plantations on which           
          jojoba was already being grown.  He also visited a research                 
          facility located at the University of California at Riverside               
          which was involved in the growing of jojoba.  On these trips, Mr.           
          Trimboli met with Robert Cole, who would become the general                 


          2(...continued)                                                             
          partnership for taxable year 1983.                                          





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