- 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