- 7 - 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 thePage: 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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