Jackie H. Hunt - Page 2




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          effect for the year in issue, and all Rule references are to the            
          Tax Court Rules of Practice and Procedure.                                  
               The issues for decision are:  (1) Whether petitioner is                
          liable for additions to tax for negligence under section 6653(a);           
          (2) whether petitioner is liable for the addition to tax for a              
          substantial understatement under section 6661; (3) whether this             
          Court has jurisdiction to review the section 6621(c) tax-                   
          motivated interest assessed by respondent and remaining unpaid by           
          petitioner; and (4) if this Court does have jurisdiction to                 
          review the tax-motivated interest, whether such interest was                
          properly assessed in this case.1  The issues in this case concern           
          petitioner’s participation as a limited partner in Yuma Mesa                
          Jojoba, Ltd. (Yuma Mesa or the partnership).2                               

          1In her petition, as twice amended, petitioner raised the                   
          additional issues of (1) alleged errors by respondent in                    
          determining the correct amount of interest; (2) the possible                
          applicability in this case of sec. 6404(g), regarding suspension            
          of interest and penalties; and (3) the denial of a request for              
          abatement of interest.  Petitioner, however, did not include                
          these issues in either her trial memorandum or her post-trial               
          brief.  We therefore consider them to have been abandoned.                  
          2The underlying deficiency in this case is based upon a                     
          computational adjustment made by respondent in accordance with              
          partnership level adjustments.  Those adjustments were upheld by            
          this Court in Cactus Wren Jojoba, Ltd. v. Commissioner, T.C.                
          Memo. 1997-504.  In that case, this Court reviewed respondent’s             
          determinations with respect to Yuma Mesa and a related                      
          partnership.  We held that the partnerships did not directly or             
          indirectly engage in research or experimentation and that the               
          partnerships lacked a realistic prospect of entering into a trade           
          or business.  In upholding respondent’s disallowance of                     
          $1,298,031 in research and experimental expenditures claimed by             
                                                             (continued...)           





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