- 4 - partnership investments that are closely related to the limited partnership investment at issue herein. Background and other general facts as they were found in Krause that relate directly and indirectly to the partnership investments involved herein we, by this reference, incorporate as findings of fact in the instant case. At the time his petition was filed, petitioner resided in Greenville, Delaware. Of the total $75,909,492 cumulative losses reported by Drake on its Federal partnership income tax returns for 1981 through 1984 and passed through to the limited partners of Drake, $72,620,000 related to the EOR license fees purportedly owed by Drake. In Krause v. Commissioner, supra, we analyzed in detail the various EOR technology license and lease agreements and the purported partnership debt obligations relating thereto that were entered into by various of the limited partnerships (specifically including Barton Enhanced Oil Production Income Fund (Barton), which is closely related to Drake), and we analyzed the state of development of the specific EOR technology involved in the partnership license agreements. With regard to the excessive nature of the EOR technology license agreements, we concluded in Krause that -- The stated consideration agreed to by the partnerships for the license of EOR technology * * * bore noPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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