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Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue.
Background
Petitioners invested in White Rim Oil and Gas Associates,
1980 (White Rim), a Utah limited partnership that was part of a
group of tax-oriented limited partnerships that had the stated
general objective of, among other things, investing in enhanced
oil recovery technology for the recovery of oil and natural gas.
The parties herein stipulate that White Rim's transactions,
for all relevant purposes, were identical to those of Technology
Oil and Gas Associates, 1980 (Technology 1980), one of the
partnerships involved in our test case opinion in Krause v.
Commissioner, 99 T.C. 132 (1992), affd. sub nom. Hildebrand v.
Commissioner, 28 F.3d 1024 (10th Cir. 1994). Further, other than
petitioners' claim for loss deductions under section 165 with
respect to the amount of cash invested in White Rim, petitioners
agree to be bound by Krause with respect to the disallowance of
tax deductions relating to White Rim's claimed losses, interest
expense deductions, and investment credit.
When the petitions were filed, petitioners resided in New
York, New York.
During 1980, 1981, 1982, and 1983, petitioners invested in
White Rim by transferring to White Rim $75,000 in cash and by
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Last modified: May 25, 2011