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Some of the facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. Petitioners resided in
Dallas, Texas, on the date the petition was filed in this case.
In 1982 and at the time of trial, petitioner husband (Mr.
Robnett) was practicing as a dentist. He operated his practice
as a corporation and supervised two other employees. Petitioner
wife (Ms. Robnett) assisted her husband in his office on a part-
time basis in 1982 and worked as a receptionist in her husband’s
office at the time of trial. Mr. Robnett spent 4 years in
undergraduate education and 3 years earning his dentistry degree.
Ms. Robnett received a 4-year degree in elementary education and
spent 5 years teaching.
Although Ms. Robnett knew of the existence of jojoba and
some of its uses prior to the investment, she first learned of
the jojoba investment opportunity from petitioners’ accountant,
Mr. Ray Meinke. Mr. Meinke prepared petitioners’ tax return for
1982 and had been preparing their returns since 1958, the year in
which petitioners were married. He suggested to petitioners that
they invest in Yuma Mesa as a means to set aside money for
2(...continued)
entered into by the partnership as “mere window dressing,
designed and entered into solely to decrease the cost of
participation in the jojoba farming venture for the limited
partners through the mechanism of a large upfront deduction for
expenditures that in actuality were capital contributions.” Id.
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