Cactus Wren Jojoba, Ltd., Cecil R. Almand, Tax Matters Partner - Page 4

                                                 - 4 -                                                   
                                          FINDINGS OF FACT                                               
                  Some of the facts have been stipulated and are so found.                               
            The stipulation of facts and the exhibits attached thereto are                               
            incorporated herein by this reference.                                                       
                  The jojoba plant is a shrub that is native to the Sonora                               
            Desert region in Arizona, California, and Mexico.  A jojoba plant                            
            may live more than 100 years.  The female jojoba plant produces a                            
            seed, sometimes referred to as a bean, that contains                                         
            approximately 50 percent by weight of an unusual oil.  Jojoba oil                            
            is actually a liquid wax ester, unlike the triglyceride oils                                 
            typically produced by plants, and is similar to sperm whale oil.                             
                  It takes 5 years or more for a jojoba plant to produce seeds                           
            in a harvestable quantity.  Approximately 20 pounds of jojoba                                
            seeds are needed to produce 1 gallon of jojoba oil.  Jojoba oil                              
            is useful for a variety of purposes, ranging from cosmetics and                              
            shampoos to industrial lubricants.                                                           
                  The ban in 1971 on the importation of sperm whale oil and                              
            products using that oil stimulated an interest in the commercial                             
            production of jojoba oil.  During the 1970's and the early                                   
            1980's, jojoba oil was available only from native jojoba plants.                             
            At that time in the United States, there were only a few                                     
            commercial-size jojoba plantations, all of which were in                                     
            developmental stages.  Domestication studies were being conducted                            
            in the United States during that time at the University of                                   
            California at Riverside and the University of Arizona, among                                 




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