Pelle Karlsson and EvelynT. Karlsson - Page 6

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                  supported by credible expert testimony in this case and                             
                  were not reasonable.  [Id. at 169; citations omitted.]                              

                  With regard to the lack of development of the EOR                                   
            technology, we stated in Krause that the --                                               

                  portfolio [of EOR technology] consisted of a package of                             
                  vague, largely untested ideas, that, if and to the                                  
                  extent ever developed, would likely be available                                    
                  generally in the marketplace and on much more favorable                             
                  terms than from the partnerships.  We reject                                        
                  petitioners' argument that the portfolio of EOR                                     
                  technology obtained by the partnerships represented                                 
                  anything of any substantial value.  The EOR technology                              
                  license agreements entered into * * * were essentially                              
                  valueless.  [Id. at 175.]                                                           

                  With regard to the lack of validity of the debt obligations                         
            of the partnerships, we stated in Krause that --                                          

                        The multimillion dollar license fees and royalties                            
                  * * * were excessive.  They did not reflect arm's-                                  
                  length obligations, and they are not to be recognized                               
                  as legitimate obligations of the partnerships.  The                                 
                  debt obligations of the partnerships associated                                     
                  therewith did not constitute genuine debt obligations                               
                  and are to be disregarded.  [Id. at 175; citations                                  
                  omitted.]                                                                           

                  In summary, in Krause v. Commissioner, supra, among other                           
            things, we concluded that the partnerships, the various license                           
            and lease agreements, the EOR technology, and the purported debt                          
            obligations of the partnerships constituted nothing more than an                          
            elaborate tax shelter scheme, as follows:                                                 







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