- 9 - 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, whichPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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