Rodney M. Fujiyama and Vicki Ann Fujiyama - Page 3




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               Respondent determined that petitioners are liable for an               
          addition to tax for negligence under section 6653(a)(2) for 1982.           
          The only issue for decision is whether petitioners are liable for           
          the addition to tax for negligence pursuant to section 6653(a)(2)           
          for 1982 in the amount of 50 percent of the interest due on the             
          underlying deficiency of $6,479,2 which respondent computed in              
          connection with the disallowance of research and development                
          expenditures deducted in 1982 by Jojoba Research Partners,                  
          Hawaii, a limited partnership.                                              
                                     Background                                       
               Some of the facts have been stipulated and are so found.  We           
          incorporate the stipulation of facts by this reference.                     
          Petitioners resided in Honolulu, Hawaii, on the date the petition           
          was filed.  Hereinafter, references to petitioner are to Rodney             
          M. Fujiyama.                                                                
               Petitioner graduated from law school and has been licensed             
          to practice law since 1970.  Petitioner’s legal practice focuses            
          primarily on business transaction planning.  Petitioner does not            
          practice tax law and has very little tax experience.  When one of           
          petitioner’s clients requires tax advice, petitioner engages the            
          services of a national or local accounting firm to assist him.              


               2In his notice of deficiency, respondent determined that               
          petitioners are liable for a negligence penalty in the amount of            
          50 percent of the interest due on $13,367.  Respondent conceded             
          in his trial memorandum that the penalty should be limited to 50            
          percent of the interest due on $6,479.                                      





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