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In comparing the cost of investing in Cromwell and the cost
of investing in Technology-1980 and the due dates of the various
debt obligations, Bursell erroneously assumes that the $80,000
portion of Cromwell’s debt obligation for each partnership unit
that was reflected by a nonrecourse promissory note actually
would be paid.
Bursell points out that Cromwell’s $120,000 promissory notes
are not due until 2007, while the promissory notes of Technology-
1980 were due between 1992 and 1995. We agree with respondent
that this distinction is meaningless in the context of the tax
sheltered and speculative transaction before us. If anything,
the extended due date for the Cromwell promissory notes suggests
that Cromwell’s promissory notes were even more contingent than
those of Technology-1980.
The distinction that Glenda Exploration and Development
Corp. (GEDCO) was the managing general partner of Cromwell but
only the cogeneral partner of Technology-1980 is not significant.
GEDCO's role in all of the related partnerships effectively was
the same.
The fact that Cromwell offered fewer partnership units than
Technology-1980 is meaningless. All of the partnerships offered
different numbers of partnership units.
Petitioners inaccurately allege that Cromwell was not
restricted in its use of the EOR technology on the leased tar
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Last modified: May 25, 2011