Court of Appeals for the Tenth Circuit June 22, 1994, Nos. 93-9010, 93-9011 (Hildebrand v. Commissioner)

TACHA, Circuit Judge.

The taxpayers in these consolidated cases, R.A. Hildebrand and Dorothy A. Hildebrand Wahl (the “Hildebrands”) and Gary E. Krause (“Krause”), tax matters partner of Barton Enhanced Oil Production Income Fund (“Barton Income Fund”), appeal the *1026Tax Court’s disallowance under 26 U.S.C.