- 6 - general partners of Yuma Mesa, and Woodburn was TMP.5 No investments in Yuma Mesa were made prior to December 31, 1982, and no activity, other than document execution, concerning Yuma Mesa occurred during 1982. The parties have stipulated that Yuma Mesa began business on December 31, 1982. Using the accrual method of accounting and an election under section 174, Yuma Mesa deducted $1,298,031 as research and development expenses for the taxable year ending on December 31, 1982. However, no activity under the research and development agreement occurred prior to December 31, 1982. In 1982, Woodburn and Sullivan were partners in the law firm of Woodburn and Sullivan located in Dallas, Texas. Sometime in 1982, one of the principals of the accounting firm Meinke, Damer, and Peterson6 (Meinke firm) approached Sullivan or Woodburn regarding the possibility of having both of them serve as the general partners of a limited partnership with a described purpose of conducting research and development of the jojoba plant and its product, the jojoba nut (or bean). Sullivan and Ray Meinke (Meinke), had known each other since Sullivan's graduation from law school in 1963. Over the years, they 5 William Woodburn retired in 1985 for health reasons and resided in Hawaii at the time of trial. His co-general partner, G. Dennis Sullivan (Sullivan), testified at trial. Sullivan is a party to these cases pursuant to sec. 6226(c) and (d). 6 The principals were Raymond Meinke (Meinke), Keith Damer (Damer), and Marlin Peterson (Peterson).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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