Janet L. Wiest - Page 4




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          negligence or intentional disregard of rules or regulations.  We            
          hold that petitioner is liable for such additions.                          
               (2) Whether petitioner is liable for the addition to tax               
          under section 6661 for substantial understatement of tax                    
          liability.  We hold that petitioner is liable for such addition.            
               The foregoing two issues relate to the participation of                
          petitioner as a limited partner in a jojoba partnership known as            
          San Nicholas Research, Ltd.                                                 
                                     Background                                       
               Some of the facts have been stipulated, and they are so                
          found.  The stipulated facts and attached exhibits are                      
          incorporated herein by this reference.                                      
               Petitioner resided in Riverside, California, at the time               
          that his petition was filed with the Court.                                 
          A.  Petitioner’s Background and Experience                                  
               After graduating from high school in 1955, petitioner                  
          attended San Bernardino Valley Junior College for 1 year and                
          California State University at Long Beach for an additional year.           
          While in college, petitioner majored in industrial arts.  He did            
          not take any business or accounting courses, nor did he take any            
          courses in either Federal or State taxation.                                
               During 1983, the taxable year in issue, petitioner’s                   
          principal occupation was part owner and operator of a successful            
          equipment rental company known as Wiest Rentals in Riverside,               






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Last modified: May 25, 2011