Great Plains Gasification Associates, A Partnership, Transco Coal Gas Company, A Partner Other Than The Tax Matters Partner - Page 5

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                                  FINDINGS OF FACT                                    
               When the petition was filed, the partnership’s principal               
          place of business was in Houston, Texas.4                                   
          Evolution of the Great Plains Project                                       
               In the 1970s, natural gas shortages were widespread.  Energy           
          companies began investigating new supply sources.  One idea was             
          to use abundant domestic coal reserves to produce synthetic                 
          natural gas in a process known as coal gasification.                        
               American Natural Resources Co. (ANRC), operated two natural            
          gas distribution companies and two natural gas pipelines, in                
          addition to conducting oil and gas exploration.  It also owned              
          rights in extensive coal reserves in North Dakota.  ANRC had                
          studied the possibility of building a coal gasification plant               
          near these coal reserves.  (This project would later become known           
          as Great Plains.)  By the mid-1970s, ANRC was working on coal               
          gasification technologies and discussing the potential project              
          with Government officials.                                                  
               Outside the United States, some coal gasification projects             
          were already operational, but existing technologies allowed coal            
          to be converted only into 500 Btu gas.  United States pipelines,            
          by contrast, required 1,000 Btu gas.  ANRC, as well as other                
          domestic energy companies, contemplated a project that would be             

               4 The parties have stipulated that pursuant to sec. 7482(b)            
          venue lies in the U.S. Court of Appeals for the Fifth Circuit.              

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