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Petitioner contends that he was reasonable in claiming
deductions and a business energy credit with respect to EI's
investment in Clearwater. To support his contention, petitioner
alleges the following: (1) That claiming the deductions and
credits with respect to EI's investment in Clearwater was
reasonable in light of a so-called oil crisis in the United
States in 1981; (2) that in claiming the deductions and credits,
he specifically relied upon Efron; and (3) that he was a so-
called unsophisticated investor.
Petitioner argues, in general terms, that an alleged oil
crisis in the United States in 1981 excuses him from the
negligence additions to tax with respect to his investment in
Clearwater through EI. Petitioner failed to explain how the so-
called oil crisis provided a reasonable basis for him to invest
in Clearwater and claim the associated tax deductions and
credits. We find petitioner's vague, general claims concerning
the so-called oil crisis to be without merit.
Petitioner's reliance on Krause v. Commissioner, 99 T.C. 132
(1992), affd. sub nom. Hildebrand v. Commissioner, 28 F.3d 1024
(10th Cir. 1994), is misplaced. The facts in the Krause case are
distinctly different from the facts of this case. In the Krause
case, the taxpayers invested in limited partnerships whose
investment objectives concerned enhanced oil recovery (EOR)
technology. The Krause opinion notes that during the late 1970's
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