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engineer to review the offering materials. Id. at 166. In the
present cases, Black testified that he has no formal background
or education in plastics engineering or plastics processing,
although he is knowledgeable about polyethylene "for the purposes
of selling machinery", and nothing in the records indicates that
Bennett had any experience or knowledge in plastics or plastics
recycling. Moreover, although they had the personal ability to
do so and the resources to have it done, petitioners did not
independently investigate the Sentinel EPE recyclers. They did
not hire an expert in plastics to evaluate the Empire transaction
either. We consider petitioners' arguments with respect to the
Krause case inapplicable.
Petitioners' reliance on Rousseau v. United States, 91-1
USTC par. 50252 (E.D. La. 1991), is similarly misplaced. In
Rousseau, the property underlying the investment, ethanol
producing equipment, was widely considered at that time to be a
viable fuel alternative to oil and its potential for profit was
apparent. In addition, the taxpayer therein conducted an
independent investigation of the investment and researched the
market for the sale of ethanol in the United States. In
contrast, as we noted in distinguishing the Krause case, there is
no showing in these records that the so-called energy crisis
would provide a reasonable basis for petitioners' investing in
the polyethylene recyclers here in question. See supra pp. 16-
17. Petitioners did not independently investigate the Sentinel
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