Dolores J. Myers - Page 10




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               On October 10, 1993, Mr. Matsuda, in his capacity as                   
          Jojoba’s TMP, entered into a stipulation with respondent agreeing           
          to be bound by this Court’s decision in Utah Jojoba I Research v.           
          Commissioner, T.C. Memo. 1998-6.  The facts regarding the                   
          underlying deficiency in Utah Jojoba I Research are substantially           
          identical to those in this case.  In Utah Jojoba I Research, we             
          held that the partnership was not entitled to deduct its losses             
          for research and development expenditures under section 174.  On            
          June 17, 1998, we entered a decision against Jojoba, the                    
          partnership involved in this case, adjusting the partnership                
          items of Jojoba by disallowing the research and development                 
          expense deduction claimed for 1982 and upholding adjustments to             
          Jojoba’s reporting position regarding management fees and                   
          interest income for taxable years 1983 through 1986.                        
          Tax Returns                                                                 
               For the taxable years 1982 and 1983, Jojoba allocated                  
          ordinary losses of $18,159 and $1,685, respectively, to the                 
          Myerses, as reflected in their 1982 and 1983 Schedules K-1,                 
          Partner’s Share of Income, Credits, Deductions, etc., issued by             
          Jojoba, which the Myerses deducted on their 1982 and 1983 Federal           
          income tax returns, respectively.                                           
               For each of the taxable years 1985 and 1986, Jojoba                    
          allocated an ordinary loss of $1,685 to petitioner, as reflected            
          in her 1985 and 1986 Schedules K-1, issued by Jojoba, which                 






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