- 7 - partnership investments in, and the activities of, Barton as described and as found in Krause. On the basis of the evidence admitted at the hearing on the show cause order and for the reasons stated below, we conclude that, for Federal income tax purposes, petitioner’s limited partnership investment in Drake, the activities of Drake, and the purported debt obligations of Drake are not distinguishable from the investments in, the activities of, and the purported debt obligations of Barton as described in the Krause opinion. Discussion In late 1978 or 1979, Winsor Savery, Richard B. Basile, E. Barger Miller, Werner Heim, Robert Shaftan, William Conklin, and other tax shelter promoters who had no significant experience with oil and gas investments began forming tax shelter limited partnerships (including Drake and Barton) with the stated general investment objectives of drilling for oil and natural gas and of obtaining the rights to certain EOR technology that might be developed and become valuable if oil prices continued to rise dramatically in subsequent years. Partnerships were formed each year from 1979 through 1984, with slight differences in general partners, structure, properties, and activities depending on the year the partnerships were formed. Drake was formed as a 1981 Denver partnership with Louis Coppage as the individual general partner. Barton was formed as a 1982 Wichita partnership with Gary Krause as thePage: 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