William R. and Betty O. Bass - Page 2

                                        - 2 -                                         
                          Additions to Tax                                            
          Year    Sec. 6653(a)(1)    Sec. 6653(a)(2)    Sec. 6661                     
          1982         $351                 *             $1,755                      
          *  50 percent of the interest on $7,020.                                    
          The notice also included a statement that interest would accrue             
          and be assessed at 120 percent of the underpayment rate in                  
          accordance with section 6621(c).  The additions to tax resulted             
          from a final partnership proceeding involving a jojoba plant                
          venture known as Cal-Neva Partners (Cal-Neva).  Unless otherwise            
          indicated, all section references are to the Internal Revenue               
          Code in effect for the year in issue, and all Rule references are           
          to the Tax Court Rules of Practice and Procedure.                           
                                  FINDINGS OF FACT                                    
               Petitioners resided in Georgia at the time that they filed             
          their petition.  In 1982, William R. Bass (petitioner) was                  
          employed by Lockheed Corp. as an accountant, and Betty O. Bass              
          was employed by the Institute of Basic Youth Conflict as a                  
               On or about December 23, 1982, petitioners paid $5,000 for a           
          limited partnership interest in Cal-Neva.  The $5,000 was paid in           
          reliance on representations by two persons associated with Cal-             
          Neva whom petitioner met during a business trip to Nevada.                  
          Petitioner did not consult any independent persons regarding the            
          viability of the jojoba plant venture or the claimed tax                    

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