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Mr. Kellen was a general partner and tax matters partner of
four limited jojoba partnerships: Utah Jojoba Research, Ltd.
(Utah Jojoba); Blythe Jojoba I Research, Ltd. (Blythe Jojoba I);
Blythe Jojoba II Research, Ltd. (Blythe Jojoba II); and Desert
Center Jojoba Research, Ltd. (Desert Center Jojoba). Each of
these partnerships was similar, if not identical, to San Nicholas
Research, Ltd., described infra in “E” through “H”.
Prior to 1982, Mr. Kellen did not have any experience in
growing jojoba, nor did he have any experience in either the
research or development of jojoba. Prior to 1982, Mr. Kellen’s
knowledge concerning jojoba 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. Mr. Kellen did not
consider himself to be an expert in jojoba in 1983.
In 1983, Mr. Kellen was actively engaged in the practice of
law, specializing in the formation of financial institutions such
as banks, savings and loan associations, and thrift and loan
associations. Mr. Kellen did not have any expertise in
accounting or tax matters, nor did he ever attempt to render
advice on those subjects.
C. Petitioner’s Friend and Associate E.T. Jacobs
E.T. Jacobs (Mr. Jacobs) was petitioner’s friend and
business associate. Like petitioner, Mr. Jacobs was a member of
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