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was activity to discover information that would eliminate
uncertainty regarding the commercialization of jojoba
plantations. Eberhardt was not aware of the manner in which HJI
purportedly allocated different plots of jojoba plants to various
limited partnerships. As far as he knew, IAS performed its
services for HJI.
3. Marvin T. Parr
Marvin T. Parr (Parr) testified for respondent as to the
merits of any research or experimentation activities HJI may have
conducted for JDP. Parr is an engineer employed by the Internal
Revenue Service in Montgomery, Alabama. He visited the TJV
plantations and inspected the growing jojoba. He is qualified to
testify as an expert in the instant cases as to the matters set
forth in his report.
Parr concluded that the activities performed on Turtleback I
between January 1, 1982, and December 31, 1986, were
predominately aimed at the creation of an existing mature jojoba
farm and were not simply directed at acquiring information about
jojoba that was unknown at the time. He also concluded that the
activities would not have eliminated any uncertainty regarding
the commercialization of jojoba because during that period jojoba
was being grown in other locations both without and within the
United States, and there were conflicting results about the
benefits of nutrients, especially with respect to nitrogen. The
conflict in the results was that in some locations the jojoba had
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