Pelle Karlsson and EvelynT. Karlsson - Page 5

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            royalties, licensing fees, and stated interest) and credits on                            
            their joint Federal income tax returns:                                                   

                  Year              Losses Claimed                Credits Claimed                     
                  1979              $119,481                      $ -                                 
                  1980              136,507                       132                                 
                  1981              130,215                       208                                 

                  In Krause v. Commissioner, 99 T.C. 132 (1992), we analyzed                          
            in detail the various EOR technology license and lease agreements                         
            and the purported partnership debt obligations relating thereto                           
            that were entered into by various of the limited partnerships                             
            (specifically including the license and lease agreements                                  
            Technology Oil and Gas Associates 1980 (Technology-1980) entered                          
            into with Elektra Energy Corp. (Elektra) and with TexOil                                  
            International Corp. (TexOil)), and we analyzed the state of                               
            development of the specific EOR technology involved in the                                
            partnership license agreements.                                                           
                  With regard to the excessive nature of the EOR technology                           
            license and lease agreements, we concluded in Krause that --                              

                  The stated consideration agreed to by the partnerships                              
                  for the license of EOR technology and for the lease of                              
                  tar sands properties bore no relation to the value of                               
                  that which was acquired, did not conform to industry                                
                  norms, and precluded any realistic opportunity for                                  
                  profit.                                                                             
                  * * * the estimates used by the partnerships for                                    
                  projected oil recovery from the use and application of                              
                  the EOR technology licensed by the partnerships are not                             





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