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not materially different or more valuable than acreage assigned
to Technology-1980. Like the tar sands acreage assigned to
Technology-1980, none of the tar sands acreage assigned to
Cromwell had any reserves or value as of 1979.
General explanatory material relating to the oil crisis of
the late 1970's and early 1980's and a detailed explanation of
the EOR technology involved in these cases are set forth in
Krause and will not be repeated herein. See Krause v.
Commissioner, supra at 134-136, 157-165.
Before investing in Cromwell, neither petitioners nor anyone
hired or otherwise engaged on petitioners' behalf visited or
inspected any of the Cromwell gas well sites in Louisiana or
Cromwell's tar sands properties.
As in Krause, petitioners' experts rely on irrelevant
generalities and theoretical exercises, ignoring crucial facts or
making erroneous assumptions. Some of the claimed differences
are based on pointless mathematical exercises. For example,
petitioners' expert, Charles G. Bursell, calculates that, per
investor dollar, Cromwell received from its tar sands leases in
excess of three times the oil-in-place that Technology-1980
received. Bursell's attempt to make Cromwell appear the better
investment simply fails to address the real problems in the
transaction between Cromwell and TexOil, including the fact that
the leased tar sands acreage had no value.
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