Rodney M. Fujiyama and Vicki Ann Fujiyama - Page 8




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          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 to                








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