- 6 -
The General Partner anticipates that a substantial
portion of the capital contributions of the Limited
Partners to the Partnership will be used for research
and experimental expenditures of the type generally
covered by Section 174 of the Code. However,
prospective investors should be aware that there is
little published authority dealing with the specific
types of expenditures which will qualify as research or
experimental expenditures within the meaning of Section
174, and most of the expenditures contemplated by the
Partnership have not been the subject of any prior
cases or administrative determinations.
* * * * * * *
No ruling by the Service has been or will be sought
regarding deductibility of the proposed expenditures
under Section 174 of the Code.
Before investing in Jojoba, Mr. Myers and petitioner
discussed whether it was an appropriate addition to their
retirement investments. On the basis of their own projections,
they concluded it was. Mr. Myers and petitioner estimated an
initial investment of approximately $20,000 in Jojoba would
produce an annual stream of income of approximately $20,000,
beginning after the jojoba beans reached maturity and were
processed--6 or 7 years from the date of investment. Although
petitioner was aware there might be agricultural problems, she
believed that jojoba beans did not require a lot of maintenance
and that there would be a market for jojoba products. She had
seen jojoba products in stores and had read an article about
jojoba beans being used in foods.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011