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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 the
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