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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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