- 3 -
addition.
The foregoing two issues relate to the participation of
Anthony N. Finazzo (petitioner) as a limited partner in a jojoba
partnership known as San Nicholas Research, Ltd.
FINDINGS OF FACT
Some of the facts have been stipulated, and they are so
found. The stipulated facts and attached exhibits are
incorporated herein by this reference.
Petitioners resided in Fontana, California, at the time that
their petition was filed with the Court.
A. Petitioners’ Background and Experience
Petitioner graduated in 1953 from Chaffey Junior College in
Ontario, California, with an associate of arts degree. He then
attended the University of California at Los Angeles for 1 year
where he took basic courses in business administration, including
accounting, economics, and investing. Petitioner never took
courses in either Federal or State taxation, nor did he ever take
courses related to either farming or agriculture.
Petitioner is a successful businessman. Prior to 1983,
petitioner served for 11 years as chairman of the board of
directors of Fontana First National Bank; he also served as
branch manager for several other financial institutions. In
1983, the taxable year in issue, petitioner was the general
manager and 25-percent owner of Midway Honda-GMC Inc., a highly
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