- 2 -
Krause involved limited partnership investments related to and
similar to those in which petitioner herein invested and which
are at issue in this case. See also Karlsson v. Commissioner,
T.C. Memo. 1997-432, and Vanderschraaf v. Commissioner, T.C.
Memo. 1997-306, which also involved partnership investments and
issues related to and similar to those in which petitioner herein
invested and which resolved the issues in a manner consistent
with Krause.
Respondent determined a deficiency in petitioner’s Federal
income tax and additions to tax as follows:
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6653(a)(1) 6653(a)(2) 6661
1982 $364,452 $18,223 * $36,445
* 50 percent of interest due on portion of underpayment
attributable to negligence.
Unless otherwise indicated, all section references are to
the Internal Revenue Code, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
Petitioner invested in Drake Oil Technology Partners
(Drake), a Pennsylvania limited partnership that was part of a
group of tax-oriented limited partnerships with the stated
general objective of, among other things, investing in enhanced
oil recovery (EOR) technology for the recovery of oil and natural
gas.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011