William R. and Betty O. Bass - Page 4
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agreement that the outcome of the Cal-Neva case was to be
determined in accordance with the outcome of Utah Jojoba I
Research v. Commissioner, docket No. 7619-90. On January 5,
1998, the Court’s opinion in Utah Jojoba I Research v.
Commissioner, T.C. Memo. 1998-6 (Utah Jojoba I Research), was
filed, and, pursuant to that opinion, a decision sustaining
respondent’s adjustments was entered on January 8, 1998, in that
At the time the decision in Utah Jojoba I Research became
final, the tax matters partner in the Cal-Neva case, Benham,
could not be located. Ultimately, respondent filed a Motion for
Entry of Decision in accordance with the Stipulation to be Bound.
By order dated February 1, 2005, the partners of Cal-Neva were
directed to show cause why respondent’s Motion for Entry of
Decision should not be granted. No response to the Court’s order
was received. Decision in the Cal-Neva case, docket No. 6594-87,
was entered April 11, 2005. A copy of the decision was served on
petitioner. The decision in docket No. 6594-87 became final
July 11, 2005. The notice in the instant case was sent June 19,
2006, within 1 year of finality of the partnership proceeding.
The additions to tax in issue here were based on $7,020, which
the Internal Revenue Service (IRS) determined to be the
deficiency in income tax attributable to the Cal-Neva deductions
claimed by petitioners on Schedule C of their 1982 return.
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Last modified: March 27, 2008