- 5 -
Vancouver Coors, Inc.4
B. Petitioner’s Initial Involvement in Jojoba Partnerships
In late 1982, petitioner became the general partner and tax
matters partner of four limited partnerships: Utah Jojoba
Research, Ltd. (Utah Jojoba); Blythe Jojoba I Research, Ltd.
(Blythe Jojoba I); Blythe Jojoba II Research, Ltd. (Blythe Jojoba
II); and Desert Center Jojoba Research, Ltd. (Desert Center
Jojoba).5 Each of these partnerships was similar, if not
identical, to San Nicholas Research, Ltd., described infra pp.
5-11.
Prior to 1982, petitioner did not have any experience in
growing jojoba, nor did he have any experience in either the
research or development of jojoba. Prior to that time,
petitioner’s knowledge concerning jojoba was limited to articles
that he had read in various magazines and a general familiarity
with the existence of an experimental jojoba plantation located
at the University of California at Riverside.
4 At trial, petitioner testified that he became a general
partner in Coordinated Financial Services (CFS) of Salt Lake
City, Utah “in the latter part of 1982.” The record is not clear
whether petitioner continued to be a partner in CFS in 1983. CFS
is described in Utah Jojoba I Research v. Commissioner, T.C.
Memo. 1998-6; see infra pp. 12-14.
5 Petitioner also became a limited partner in Desert Center
Jojoba.
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