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liability. We hold that petitioner is liable for such addition.
The foregoing two issues relate to the participation of
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.
Petitioner resided in Cora, Wyoming, at the time that his
petition was filed with the Court.
A. Petitioner’s Education and Experience
Petitioner is a highly educated individual. In 1964, he
graduated from Loyola University of Los Angeles with a bachelor
of science degree in civil engineering, specializing in water
systems. Ten years later, in 1974, he received a law degree from
Western State College of Law in Fullerton, California.
Since 1964, petitioner has practiced engineering in both the
public and private sectors. Since 1974, he has practiced law in
the private sector.
Petitioner also has experience related to farming. In 1974,
he formed a company known as the Great American Hay Company that
grew hay in Desert Center, California. In 1975, he and certain
friends and investors purchased property known as Brown’s Farm
that grew citrus, alfalfa, and row crops.
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