- 3 - FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts, the supplemental stipulation of facts, the stipulation of settled issues, and the attached exhibits are incorporated herein by this reference. Petitioner resided in Boulder, Colorado, at the time he filed his petition. In 1980, petitioner invested in Sav-Fuel Associates (Sav- Fuel), a Connecticut limited partnership.3 During the years in issue, petitioner, as a limited partner, had a 2.152174-percent interest in the profits and losses of Sav-Fuel. The sole general partner of Sav-Fuel was Winston Frost (Mr. Frost), who held a 1- percent interest in the profits and losses of the partnership. A private placement memorandum (PPM) for Sav-Fuel was distributed to potential investors. The stated purpose of Sav-Fuel was to acquire an energy management system (EMS) to be installed in the manufacturing plant of Gould, Inc. (Gould), located in El Monte, California. The EMS was to include master controllers, control modules, heat exchangers, fans, valve controls, an automated lighting control system, and other devices and controls. The stated function of the EMS was to provide a technologically advanced yet simple and 3The evidence in the record indicates that Sav-Fuel was formed on July 1, 1980.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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