- 4 - Background At the time their petitions were filed, petitioners resided in Santa Ana, California. In Sweden, petitioner Pelle Karlsson obtained the approximate equivalent of a U.S. high school diploma. In the United States, petitioner Evelyn T. Karlsson obtained a high school diploma through the general educational development exam. Neither petitioner has a college degree, and neither petitioner has been enrolled in any courses or received any training in petroleum engineering, drilling technology, or geology. Neither petitioner has ever been employed in or had any professional involvement in the oil and gas industry. In 1979, petitioners invested in Cromwell by transferring to Cromwell $30,000 in cash and by executing in favor of Cromwell promissory notes in the total face amount of $420,000. On the basis of such cash investment, the stated face amount of such promissory notes, and petitioners’ stated obligation on Cromwell’s debt obligations, petitioners claimed for the years in issue the following tax losses (consisting largely of accruedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011