- 4 - 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 case. 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008