- 9 - Mr. Cannito also prepared petitioners’ 1984 joint Federal income tax return, claiming a deduction for another loss arising from the Arid Land investment in the amount of $798. As the result of partnership level proceedings concerning Arid Land Research Partners, this Court ultimately entered a decision disallowing in full the partnership’s claimed ordinary loss in each of the taxable years 1983 and 1984. This decision was based upon a stipulation by the partnership and the Commissioner to be bound by the outcome of the case in which this Court rendered our opinion in Utah Jojoba I Research v. Commissioner, T.C. Memo. 1998-6. In that case, we found that the Utah Jojoba I Research partnership (“Utah I”) was not entitled to a section 174(a) research or experimental expense deduction (or a section 162(a) trade or business expense deduction) because (a) Utah I did not directly or indirectly engage in research or experimentation, and (b) the activities of Utah I did not constitute a trade or business, nor was there a realistic prospect of Utah I ever entering into a trade or business. Id. Following the entry of the decision concerning the partnership, respondent adjusted petitioners’ returns by disallowing their claimed shares of the partnership losses, $34,739 in 1983 and $798 in 1984. In the statutory notices of deficiency which provide the basis for our jurisdiction in this case, respondent determined that petitioners are liable forPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011