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petitioner’s income tax for 1983 in the amount of $5,435 and
mailed a so-called affected items notice of deficiency to
petitioner determining additions to tax for negligence and
substantial understatement of tax liability. See sec. 6230(a);
N.C.F. Energy Partners v. Commissioner, 89 T.C. 741, 744 (1987);
Maxwell v. Commissioner, 87 T.C. 783, 792 n.9 (1986). It is
those additions to tax that are in issue in the present cases.
K. Epilogue: Demise of the Jojoba Partnerships
The jojoba partnerships proved to be financial failures. In
October 1991, some 30 to 40 jojoba partnerships under contract
with U.S. Agri were consolidated into one large limited
partnership, Jojoba Plantation Ltd. Sometime thereafter, Jojoba
Plantation Ltd. filed a petition in bankruptcy under chapter 7 of
the Bankruptcy Act. See Utah Jojoba I Research v. Commissioner,
supra.
At trial, petitioner’s witness, Mr. Kellen, testified that
the jojoba partnerships failed because of the Internal Revenue
Service.16 At a previous trial, Mr. Kellen testified that “the
collapse, basically, of the tax incentive for doing jojoba”
contributed to the partnerships’ failure. See id.
16 Petitioner’s other witness, Kathleen M. Jacobs, suggested
a different reason: That no commercially viable method of
harvesting jojoba was ever developed, or, as Ms. Jacobs
testified, that “it was impossible to harvest.”
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