A New York State Administrative Law Judge has disallowed losses arising from investments in oil and gas exploration partnerships, finding that the ventures had tax avoidance as their primary motive and had no economic substance apart from the tax benefits. Matter of Joseph and Nancy Francoforte, DTA No. 825390 (N.Y.S. Div. of Tax App., Feb. 19, 2015). The ALJ noted that the offering materials reflect “an exhaustive discussion” of the tax benefits but provided little or no information on locations or names of the wells to be drilled, the anticipated oil or gas production, or the revenues to be derived. Also, because the transactions were found to be abusive tax avoidance transactions, the extended six-year statute of limitations applied under Tax Law § 683(c)(11)(B), and the notices of deficiency were found timely, despite having been issued beyond the normal three-year statute of limitations.