- 19 - value. Austin's understanding of this transaction was minimal, and his testimony provides no credible support for petitioners' position in these cases. Petitioners have established no credible differences between Cromwell's tar sands acreage and Technology-1980's tar sands acreage. Both are worthless. It is clear that the Cromwell and Technology-1980 limited partnerships share the same flaws. The consideration that was agreed to for the EOR technology licenses and for the tar sands acreage bore no relation to the value of that which was acquired, did not conform to industry norms, and precluded any realistic opportunity for profit. Cromwell's stated debt obligations relating to the multimillion dollar license fees and royalties that Cromwell agreed to pay were excessive. They did not reflect arm’s-length obligations, and they do not constitute valid debt obligations. Krause v. Commissioner, 99 T.C. at 169. No material differences have been established or even marginally corroborated, and no credible arguments have been presented that distinguish these cases from Krause. In addition to attempting to distinguish Cromwell factually from Technology-1980, petitioners affirmatively attack as erroneous a number of our specific findings of fact in Krause. Contrary to the Krause findings, petitioners affirmatively allege: (1) The Burnt Hollow acreage constituted a heavy oilPage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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