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Empire because of rising oil prices in the United States in 1981.
Petitioners placed into the record several documents from the
period 1979 to 1981, including speeches by William L. Wearly
(Wearly), chairman of the board of Ingersoll-Rand; articles from
Modern Plastics magazine; and an energy projections report from
the U.S. Department of Energy (DOE). Wearly's speeches, given at
colleges and universities, discussed business and national policy
challenges. One of his concerns was U.S. dependency on foreign
oil. The Modern Plastics articles and DOE report speculated on
the price of oil, among other things. Petitioners failed to
explain, however, the connection between these speculative
materials and the Empire investment. We find petitioners' vague,
general claims concerning the so-called oil crisis to be without
merit.
Petitioners' reliance on Krause v. Commissioner, 99 T.C. 132
(1992) (citing Todd v. Commissioner, 89 T.C. 912 (1987), affd.
862 F.2d 540 (5th Cir., 1988), 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 these cases. 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 and early 1980's, the Federal
Government adopted specific programs to aid research and
development of EOR technology. Id. at 135-136. In holding that
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