- 6 - attorney. I don’t know whether exactly she was a practicing attorney or what. But they seemed to be people that understood enough about the investment, and that it was viable, and so I know at some point, having some knowledge of taxes on some of the past investments, I thought it would be a viable investment. So I did enter into the investment, and paid the $5,000 initial investment amount, and the rest was financed, and interest payments were made for several years, five or six years, and ultimately the partnership went under. Of course, if I had known that at the beginning, I definitely would not have been involved in it, especially since it looks like it was creating a problem from the standpoint of taxability. But at the time, it seemed to me that it was not an unusual investment to make. And so after doing the limited amount of checking that I was able to do without spending days and days, I guess, in the area where they resided. I think it was during that time that they subsequently moved to Hawaii. So my investigating from a due diligence to me was sufficient to let me know that it was a viable investment and it would stand up from a tax standpoint, and so that’s basically my statement and my testimony in that regard. In other reported cases, notably the opinion in Utah Jojoba I Research, the programs concerning Jojoba plants are described in detail. As summarized in Lopez v. Commissioner, T.C. Memo. 2001-278, affd. 92 Fed. Appx. 571 (9th Cir. 2004): In the decided case, this Court held that the partnerships did not directly or indirectly engage in research or experimentation and that the partnerships lacked a realistic prospect of entering into a trade or business. In upholding respondent’s disallowance of research and experimental expenditures, the Court foundPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008