Pelle Karlsson and EvelynT. Karlsson - Page 2

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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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