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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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Last modified: May 25, 2011