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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.
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