- 26 -
including researching EOR technology. The other taxpayer was a
geological and mining engineer whose work included research of
oil recovery methods and who hired an independent geologic
engineer to review the offering materials. Id. at 166. In the
present case, petitioner was not experienced or educated in
plastics recycling or plastics materials. He did not
independently investigate the Sentinel recyclers, and he did not
hire an expert in plastics to evaluate the Clearwater
transaction. We consider petitioner's arguments with respect to
the Krause case inapplicable and find his vague, general claims
concerning the so-called oil crisis to be without merit.
On his 1981 Federal income tax return, petitioner claimed a
business energy credit related to Clearwater in the amount of
$9,651, while his investment in Clearwater through EI was less
than $11,500.6 Because petitioner did not claim an investment
tax credit with respect to the Clearwater recyclers, the credit
claimed on his 1981 Federal income tax return related to EI's
investment in Clearwater does not exceed the amount he invested
in Clearwater through EI. In addition to the credit claimed on
6
Calculated as follows:
EI's Investment in Clearwater Petitioner's Share of EI
$350,000 x 3.194% = $11,179
EI's Investment in Clearwater
$350,000 x Petitioner's Investment = $11,290
EI's Total Investment $50,000
$1,550,000
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