- 7 - general caveats and disclaimers along with the opinion that “it is more likely than not that a partner of Arid Land Research Partners, a Limited Partnership will prevail on the merits of each material tax issue presented herein.” However, the conclusions regarding the issue of the section 174 deduction in particular were vague and nonconclusive in nature. Finally, the investor subscription agreement accompanying the private placement memorandum required a subscriber upon purchase of an interest to aver that: He understands that an investment in the Partnership is speculative and involves a high degree of risk, there is no assurance as to the tax treatment of items of Partnership income, gain, loss, deductions of credit and it may not be possible for him to liquidate his investment in the Partnership. In December 1983, petitioners purchased five units in Arid Land through Mr. Trimboli for a total of $5,500 in cash and a promissory note of $8,250. Petitioner was aware that Mr. Trimboli received a commission for his sale of the interests in Arid Land, but he did not know of any other relationship which he had with the partnership or its principals. The commissions Mr. Trimboli received for selling interests in the partnership were similar to the commissions he received for selling other types of investments. In addition to the commissions, Mr. Trimboli was retained by Arid Land to prepare the 1983 tax return for the partnership. In preparing the partnership’s return, Mr. Trimboli relied on financialPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011