- 23 - 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.Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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