- 7 - agreement with Agri-Research and Jojoba guaranteeing, to the extent of the promissory note balance, Jojoba’s liability to Agri-Research under the research and development agreement. Petitioners’ 1982 Federal Income Tax Return For the taxable year 1982, Jojoba allocated an ordinary loss of $12,971 to petitioner, as reflected in his 1982 Schedule K-1, Partner’s Share of Income, Credits, Deductions, Etc., issued by Jojoba, which petitioners deducted on their 1982 joint Federal income tax return. On October 18, 1993, the tax matters partner of Jojoba entered into a stipulation with respondent agreeing to be bound by this Court’s decision in Utah Jojoba I Research v. Commissioner, T.C. Memo. 1998-6. The facts regarding the underlying deficiency in Utah Jojoba I Research are substantially identical to those in this case. In Utah Jojoba I Research, we held that the partnership was not entitled to deduct its losses for research and development expenditures under section 174. On June 17, 1998, we entered a decision against Jojoba, the partnership involved in this case, disallowing the research and expense deduction claimed for 1982. On August 6, 1999, respondent issued a notice of deficiency to petitioners for 1982 in which he determined that petitioners are liable for an addition to tax for negligence pursuant toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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