Pelle Karlsson and EvelynT. Karlsson - Page 3

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            recovery (EOR) technology for the recovery of oil and natural                             
            gas.                                                                                      
                  After settlement of some issues, the primary issues in these                        
            cases are:  (1) Whether activities of Cromwell were engaged in                            
            for profit under section 183; (2) whether stated debt obligations                         
            of Cromwell constituted genuine debt obligations giving rise to                           
            deductible interest; and (3) whether petitioners are liable for                           
            increased interest under section 6621(c) and additions to tax                             
            under sections 6653(a)(1) and (2) and 6661.                                               
                  In the Krause test case opinion and in Vanderschraaf v.                             
            Commissioner, T.C. Memo. 1997-306, the first two of the above                             
            primary issues were decided against the taxpayers, and the third                          
            of the above primary issues was decided in favor of respondent as                         
            to the increased interest and in favor of the taxpayers as to the                         
            additions to tax.                                                                         
                  This Court uses show cause procedures in situations similar                         
            to the instant cases where the disposition of pending cases may                           
            be affected by a previously decided “test case”.  See Lombardo v.                         
            Commissioner, 99 T.C. 342, 343-345 (1992), affd. sub nom. Davies                          
            v. Commissioner, 68 F.3d 1129 (9th Cir. 1995); Gray v.                                    
            Commissioner, T.C. Memo. 1996-525; Finkelman v. Commissioner,                             
            T.C. Memo. 1994-158; Iowa Investors Baker v. Commissioner, T.C.                           
            Memo. 1992-490; Bokum v. Commissioner, T.C. Memo. 1990-21, affd.                          
            992 F.2d 1136 (11th Cir. 1993).                                                           





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