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limited partnership investments in, and the activities of,
Technology-1980, as described and as found in our Krause v.
Commissioner, supra, opinion.
For the reasons stated below and based on the evidence
admitted at the hearing on the show cause order, we conclude
that, for Federal income tax purposes, the limited partnership
investments in Cromwell and the activities of Cromwell are not
distinguishable from the investments in and the activities of
Technology-1980 as described in the Krause v. Commissioner,
supra, opinion.
Discussion
In late 1978, 1979, and early 1980's, Winsor Savery,
Richard B. Basile, E. Barger Miller, Werner Heim, Robert Shaftan,
William Conklin, and other tax shelter promoters, who had no
significant experience with oil and gas investments, participated
in the formation of tax shelter limited partnerships (including
Cromwell and Technology-1980) with the stated general investment
objectives of drilling for oil and natural gas and of obtaining
the rights to certain EOR technology that might be developed and
become valuable if oil prices continued to rise dramatically in
subsequent years.
Louis Coppage, the individual general partner of Cromwell,
also had no experience with oil and gas exploration, production,
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