Ann E. Bartak - Page 9

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               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 will                 





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