- 3 - 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,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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