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negligence or intentional disregard of rules or regulations. We
hold that petitioner is liable for such additions.
(2) Whether petitioner is liable for the addition to tax
under section 6661 for substantial understatement of tax
liability. We hold that petitioner is liable for such addition.
The foregoing two issues relate to the participation of
petitioner as a limited partner in a jojoba partnership known as
San Nicholas Research, Ltd.
Background
Some of the facts have been stipulated, and they are so
found. The stipulated facts and attached exhibits are
incorporated herein by this reference.
Petitioner resided in Riverside, California, at the time
that his petition was filed with the Court.
A. Petitioner’s Background and Experience
After graduating from high school in 1955, petitioner
attended San Bernardino Valley Junior College for 1 year and
California State University at Long Beach for an additional year.
While in college, petitioner majored in industrial arts. He did
not take any business or accounting courses, nor did he take any
courses in either Federal or State taxation.
During 1983, the taxable year in issue, petitioner’s
principal occupation was part owner and operator of a successful
equipment rental company known as Wiest Rentals in Riverside,
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