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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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