Anthony N. and Marie M. Finazzo - Page 15





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         determining additions to tax for negligence and substantial                  
         understatement of tax liability.  See sec. 6230(a); N.C.F. Energy            
         Partners v. Commissioner, 89 T.C. 741, 744 (1987); Maxwell v.                
         Commissioner, 87 T.C. 783, 792 n.9 (1986).  It is those additions            
         to tax that are in issue in the present case.                                
         J.  Epilogue: Demise of the Jojoba Partnerships                              
              The jojoba partnerships proved to be financial failures.  In            
         October 1991, some 30 to 40 jojoba partnerships under contract               
         with U.S. Agri were consolidated into one large limited                      
         partnership, Jojoba Plantation Ltd.  Sometime thereafter, Jojoba             
         Plantation Ltd. filed a petition in bankruptcy under chapter 7 of            
         the Bankruptcy Act.  See Utah Jojoba I Research v. Commissioner,             
         T.C. Memo. 1998-6.                                                           
              At trial, petitioners’ witness, Mr. Kellen, testified that              
         the jojoba partnerships failed because of the Internal Revenue               
         Service.  At a previous trial, Mr. Kellen testified that “the                
         collapse, basically, of the tax incentive for doing jojoba”                  
         contributed to the partnerships’ failure.  Id.                               
















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