Janet L. Wiest - Page 18




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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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