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(1992), affd. sub nom. Hildebrand v. Commissioner, 28 F.3d 1024
(10th Cir. 1994). Krause involved limited partnership
investments related to and similar to those in which petitioners
herein invested and which are at issue in these cases.
Respondent determined deficiencies, increased interest, and
additions to tax in petitioners’ Federal income taxes as follows:
Increased Interest and Additions to Tax
Sec.
Sec. Sec. 6653(a)/ Sec. Sec. Sec.
Year Deficiency 6621(c) 6651(a)(1)6653(a)(1) 6653(a)(2) 6659 6661
1979 $59,740 * $14,935 $2,987 -- -- --
1980 64,707 * 6,471 3,235 -- -- --
1981 70,012 * 10,5023,501 ** $21,004 --
1982 34,225 * 10,7013,381 ** 10,267 $3,423
* 120 percent of interest accruing after Dec. 31, 1984, on portion of underpayment
attributable to a tax-motivated transaction.
** 50 percent of interest due on portion of underpayment attributable to negligence.
On brief, respondent concedes the sections 6651 and 6659
additions to tax.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
Petitioners invested in Cromwell Oil and Gas Associates
(Cromwell), a Utah limited partnership that was part of a group
of tax-oriented limited partnerships that had the stated general
objective of, among other things, investing in enhanced oil
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