Steven G. Hill Parilea Hill v. Commissioner of Internal Revenue

THOMAS, Circuit Judge:

This appeal presents the question of whether the tax court correctly decided Krause v. Commissioner, 99 T.C. 132, 1992 WL 178601 (1992), a test case involving numerous limited partnerships formed to invest in enhanced oil recovery technology. The Tenth Circuit affirmed Krause in Hildebrand v. Commissioner, 28 F.3d 1024 (10th Cir.1994). We agree with the Tenth Circuit’s analysis and affirm the tax court’s judgment.

I

This appeal arises from an elaborate tax shelter constructed during the late 1970s and early 1980s. Petitioners invested, as limited partners, in Garfield Oil…