- 14 - petitioner 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, supra. At trial, petitioner testified that the jojoba partnerships failed because of the Internal Revenue Service.14 At a previous trial, petitioner testified that “the collapse, basically, of the tax incentive for doing jojoba” contributed to the partnerships’ failure. See id. 14 Petitioner’s sole third-party witness suggested a different reason: That no commercially viable method of harvesting jojoba was ever developed.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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