- 6 - the result in the Utah Jojoba I Research case at docket No. 7619- 90. The Court issued an opinion in Utah Jojoba I Research v. Commissioner, T.C. Memo. 1998-6, on January 5, 1998, holding that the partnership was not entitled to research and experimental expense deductions. The Court found that the partnership was not directly or indirectly engaged in research or experimentation, was not engaged in a trade or business, and lacked a realistic prospect of entering a trade or business. On June 4, 1999, the Court entered a decision in the Arid Land case that upheld respondent's diallowance of the partnership losses reported by Arid Land in 1983 and 1984. On July 3, 2000, respondent sent to petitioners the statutory notice in this case containing respondent's determination of their liability for the negligence additions to tax. As a result of the decision upholding the adjustments to the 1983 partnership return of Arid Land, petitioners were assessed on July 24, 2000, additional tax of $3,345. Petitioners paid the assessment on August 2, 2000. OPINION Petitioners argue that they are not subject to the additions to tax for negligence because: (1) The statute of limitations prohibits assessment of the additions to tax; and (2) theyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011