Frank E. Acierno - Page 14

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               A law firm named Somers & Altenbach received $583,555                  
          for purported legal services and for agreeing to defend, in                 
          subsequent years, tax benefits that were to be claimed in                   
          connection with the Denver-1981 partnership investments.                    
          The fee of Somers & Altenbach was based on 1-percentage point of            
          total funds raised by the five Denver-1981 partnerships.                    
               Many of the legal, economic, and technical opinions obtained           
          by Drake and the other related partnerships relied on unrealistic           
          and unreliable representations made by individuals who invested             
          in the partnerships, who were involved in promoting the                     
          partnerships, and who received fees from the partnerships based             
          on the number of limited partnership units sold.                            
               Petitioner alleges that Drake's lack of participation in the           
          TexOil tar sands acreage leased to the earlier 1979 and 1980                
          partnerships is not comparable with investments Drake (and the              
          other Denver partnerships) allegedly made in later years in                 
          other, unrelated tar sands acreage in Utah.  There is no credible           
          evidence as to how an investment in other tar sands properties              
          might justify the EOR license fees.  Petitioner’s expert, Thomas            
          Logan, provided no explanation in this regard.  There existed no            
          proven reserves in the various tar sands properties and no proven           
          methods for recovering commercial quantities of oil from the tar            
          sands.                                                                      








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