Pelle Karlsson and EvelynT. Karlsson - Page 4

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            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 accrued                             












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