Pelle Karlsson and EvelynT. Karlsson - Page 19

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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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