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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 no
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