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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 oil
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