- 5 - 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 notPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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