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different. Petitioners have not alleged any differences between
the license agreements of Boulder and Technology-1980.
We agree with respondent's expert that there were no material
differences between the various license agreements of Boulder,
Tech-1979, and Winfield and the license agreements of Technology-
1980.
Petitioners have failed to show that the applicable findings
of fact made in Krause with regard to the lack of profit objective,
the license agreements, and the nongenuine nature of the purported
debt obligations should not be applied in these cases. We conclude
that the activity and transactions of Boulder, Tech-1979, and
Winfield lacked profit objective, as did the transactions of
Technology-1980 and the other partnerships that were involved in
Krause.
In light of our resolution of the profit objective issue, it
is not necessary to address certain other substantive issues raised
by the parties.
Additions to Tax and Increased Interest
In our opinion in Krause v. Commissioner, 99 T.C. at 177-180,
we discussed at some length our reasons for not sustaining
respondent's determination of the same additions to tax that
respondent has determined with regard to petitioners herein. We
believe that that discussion, as set forth in Krause and as
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