Investor Partnerships Are a Hit. Taking part in a venture has become more affordable for the average investor.

THE Empire State Building, Paul Newman's movie ``The Color of Money,'' and the San Francisco-based Polaris Leasing Company have something in common. They are investment partnerships. Partnerships are now the main source of new equity capital in the US, surpassing corporate initial public offerings of stock by almost a 2-to-1 margin, according to the Investment Partnership Association (IPA) in Washington.

And buying into a limited partnership has become increasingly accessible for Americans. An investor can participate with as little as $500 in the case of some mutual funds or as little as $2,000 in a direct investment made through an investment adviser or broker, says Christopher Davis, president of the IPA.

In some cases, partnerships own buildings (such as the Empire State building) or movies (such as the Paul Newman film, released by a subsidiary of the Walt Disney Company). Polaris buys and leases airplanes to airlines, a practice common to the commercial aviation industry. Numerous small oil and gas companies in the United States are also owned by partnerships.

From 1982 to 1988, according to the IPA, limited partnerships in the US raised $106 billion in investment capital. During the same period, $59 billion was raised by corporations through initial public offerings of stock.

Even during the most heady days of the bull market (1985-87), partnerships overshadowed initial public offerings, says Mr. Davis. During those years, limited partnerships raised $48.7 billion in capital, compared to $36 billion for initial public offerings.

Limited partners, unlike general partners, cannot exercise control over management decisions. There were at least 9 million American partners in 1986, compared to 7.6 million in 1985. The number today is probably closer to 10 million, he adds.

The partnership concept ``resists the market fluctuations attendant on rising interest rates and inflation,'' says Davis. In other words, partnerships are ``sturdy business structures'' designed for the long haul.

THERE are even a number of generous tax advantages, for investors in a limited partnership, including depreciation allowances.

``The former tax code favored the corporation, in terms of investing decisions,'' says Marshall Blume, a professor of finance at the Wharton School of the University of Pennsylvania.

The investor buying equities in a corporation has always faced double taxation, Dr. Blume says. The corporation pays taxes and the investor pays taxes. But now various provisions of the tax code favor partnerships.

However pleasant this movement of capital toward partnerships may be for the investor, it could be mean a loss of tax revenues to the federal treasury at a time when Washington is looking for ways to reduce the federal budget deficit, Blume adds.

In the early 1980s, many limited partnerships were in fact tax shelters, notes Robert Natale, a senior investment officer at Standard and Poor's. He is not certain tax advantages are the full story behind the popularity of partnerships today. By contrast, new offerings of stock have remained quiet so far in 1989, in part because of less interest in stocks in general, adds Mr. Natale, who is editor of S&P's Emerging and Special Situations Newsletter.

The idea of partnerships goes back to the earliest days of the United States.

``The American Revolution,'' says Davis, ``[was] financed by partnerships, since the British Crown had limited the ability of the Americans to engage in corporations.''

Many of the innovations associated with the rise of the industrial revolution in the US (the works of Alexander Graham Bell and Thomas Edison, for example), grew out of partnerships.

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