Co., Ltd. According to the circulars, both limited partnerships were to sublease property from National and engage, or contract another to engage, in mining operations on the property. It appears from the record that defendant, Stanley Beck, prepared the tax opinions, leases, subleases and corporate documents and that Finkel, or his agents, prepared the remaining portions of the offering circulars. Finkel chartered Finkel Investment Service, a Florida corporation, to serve as the general partner in the Amber and Blue limited partnerships. Within a matter of weeks all limited partnership units in Amber and Blue were purchased and the partnerships were chartered.
A few months later, offering circulars were prepared for two additional limited partnerships: Diamond Coal Co., Ltd. and Emerald Coal Co., Ltd. The circulars proposed that these limitedpartnerships sublease the remaining property leased by National. Within a few weeks, the units were purchased and the partnerships chartered.
In the Fall of 1976, Kaplan, Finkel and Beck negotiated the purchase of a tract of land adjacent to the property leased by National in Bell County, Kentucky. Kaplan purchased the land and immediately leased it to Georgia National. Offering circulars for four additional limited partnerships were issued shortly thereafter. These partnerships were Crystal Coal Co., Ltd., Indigo Coal Co., Ltd., Jade Coal Co., Ltd., and Silver Coal Co., Ltd. Each circular provided that the respective limited partnership would sublease a tract of property from National when the partnership was fully subscribed and chartered. Finkel served as the individual general partner in all four partnerships.
Over a period of approximately