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The only issues2 for decision are:
1) Whether respondent is obligated to offer petitioners
terms of settlement regarding their investment in Jojoba Research
Partners, Hawaii, a limited partnership (Jojoba), consistent with
terms offered to other limited partners in Jojoba, and
2) whether petitioners are liable for the additions to tax
for negligence pursuant to section 6653(a)(1) and (2) for the
taxable years 1982, 1983, and 1985 and pursuant to section
6653(a)(1)(A) and (B) for the taxable year 1986.
Background
Some of the facts have been stipulated and are so found. We
incorporate the stipulation of facts herein by this reference.
Mrs. Myers resided in Kailua, Hawaii, on the date the petitions
were filed.
The Myerses’ Relationship With Ralph Matsuda
In 1980 or 1981, James and Dolores Myers (hereinafter
referred to individually as Mr. Myers and petitioner and
2Mrs. Myers contended she was entitled to relief from joint
and several liability in docket No. 16247-99S pursuant to sec.
6015(b), (c), or (f). On brief, however, she conceded that she
improperly brought this claim under sec. 6015. We, therefore, do
not address whether sec. 6015 is applicable herein.
Petitioners also contended that respondent improperly
offered petitioners’ settlement to the tax matters partner (TMP),
who improperly rejected that offer on petitioners’ behalf. In
light of the testimony presented at trial and petitioners’
failure to address this argument on brief other than as a
requested finding of fact, we decline to address this issue.
Rule 151(e).
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