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investment in San Nicholas. Yet, petitioner’s experience and his
knowledge should have led him to inquire into both the
operational aspects of the partnership and the nature of the
research that U.S. Agri was to conduct under the terms of the R&D
contract.19 See Fawson v. Commissioner, T.C. Memo. 2000-195.
Although petitioner claims to have visited the jojoba sites
about once a month, the primary purpose of these visits was to
“see how the plants were growing” and that proper watering and
weeding methods were being utilized. However, there is no
persuasive evidence in the record to demonstrate that petitioner,
either as a limited partner in San Nicholas or as the general
partner and tax matters partner of four other jojoba
partnerships, visited the jojoba sites in order to determine
whether research or development was being conducted. If
petitioner had visited the jojoba sites for that purpose, he
would have quickly discovered that U.S. Agri was engaged in
19 We find it curious that petitioner would choose to
emphasize his experience when the record clearly demonstrates
that prior to 1982, he did not have any experience in growing
jojoba, nor did he have any experience in either the research or
development of jojoba. Petitioner’s experience first came in
late 1982, when he became the general partner and tax matters
partner of Utah Jojoba, Blythe Jojoba I, Blythe Jojoba II, and
Desert Center Jojoba.
We find it equally curious that petitioner would choose to
emphasize his knowledge when the record demonstrates that prior
to 1982, his knowledge 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.
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