- 9 - BEWARE OF THE PITFALLS, HOWEVER. Cattle breeding is a risky business and may also bring an IRS examination because it is lowering your taxes. Another document, titled “Partnership Memorandum and Amended Agreement of Limited Partnership”, petitioner and Mr. Bartak received from the Hoyt organization contained the following statements: 2. THIS PARTNERSHIP INVOLVES CERTAIN RISKS TO THE PARTNERS, INCLUDING TAX RISKS (SEE “RISK FACTORS”) * * *. * * * * * * * 4. THE CONTENTS OF THIS MEMORANDUM ARE NOT TO BE CONSTRUED AS INVESTMENT, LEGAL OR TAX ADVICE. EACH PARTNER SHOULD CONSULT HIS OWN COUNSEL, ACCOUNTANT OR BUSINESS ADVISOR AS TO LEGAL, TAX AND RELATED MATTERS CONCERNING THIS INVESTMENT. * * * * * * * Unit holders should consider the various investment risk factors of the Partnership, which are set forth in “Risk Factors,” including the possibilities of adverse tax treatment * * *. * * * * * * * The Partnership has not received a ruling that it will be classified as a Partnership for Federal income tax purposes (See “Income Tax Consequences”). * * * * * * * CERTAIN TAX CONSIDERATIONS. In judging whether to subscribe for Units, a Partner should consider the tax consequences thereof which include, among others: (a) possible taxation of an amount in excess of proceeds actually received on the sale of the Units and/or the Partnership properties and on undistributed net income, (b) the possibility that the Partnership will not be treated as a Partnership for tax purposes * * *, (c) the possibility that the Internal Revenue Service willPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011