Pelle Karlsson and EvelynT. Karlsson - Page 7

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                        In summary, presented to us in this case is a                                 
                  chain or multilayered series of obligations, stacked or                             
                  multiplied on top of each other via the numerous                                    
                  partnerships to produce debt obligations in staggering                              
                  dollar amounts, using a largely undeveloped and                                     
                  untested product, in a highly risky, very speculative,                              
                  and nonarm's-length manner in an attempt to generate                                
                  significant tax deductions for investors.  The                                      
                  transactions did not, and do not, constitute legitimate                             
                  for-profit business transactions.  [Id. at 175-176.]                                

                  Based on our findings and opinion in Krause v. Commissioner,                        
            supra, the affirmance thereof by the U.S. Court of Appeals for                            
            the Tenth Circuit, and the denial of certiorari by the U.S.                               
            Supreme Court, thousands of investors who had invested in                                 
            Technology-1980 and in other related limited partnerships,                                
            including Cromwell, settled their Federal income tax liabilities                          
            with respondent relating to these investments.  Petitioners                               
            herein and respondent, however, have not been able to reach a                             
            settlement agreement, and petitioners allege the existence of                             
            material facts that they believe distinguish their limited                                
            partnership investments in Cromwell from the investments that                             
            were made by the taxpayers in Technology-1980 and that were                               
            specifically addressed in Krause v. Commissioner, supra.                                  
                  We issued a show cause order, and we held an evidentiary                            
            hearing in connection with our show cause order to give                                   
            petitioners an opportunity to establish how, for Federal income                           
            tax purposes, their limited partnership investments in Cromwell                           
            and how the activities of Cromwell are distinguishable from the                           





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