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deductions and investment credits with respect to their
investments in the Partnerships. In support of such contentions,
petitioners argue, in general terms: (1) That claiming the
deductions and credits with respect to the Partnerships was
reasonable in light of the so-called oil crisis during the years
in issue; and (2) that they reasonably relied upon the offering
materials and a qualified adviser. Busch's estate claims that
Busch relied exclusively on Becker, while Snyder claims to have
relied on both Becker and Miller.
1. The So-Called Oil Crisis
Petitioners argue that they reasonably believed that the
Partnership transactions had good economic potential because of
the alleged oil crisis in the United States during 1981. Snyder
contends that he knew that plastics were oil derivatives and that
his decision to invest was influenced by the media coverage of
the supposed oil crisis and the Federal Government's energy
conservation policy at the time. In his posttrial brief, counsel
for Busch's estate also refers to the so-called oil crisis as a
factor influencing Busch's decision to invest.
Petitioners fail to explain, however, exactly how the so-
called oil crisis, or the media coverage thereof, provided a
reasonable basis for them to invest in the Partnerships and claim
the associated tax deductions and credits. The offering
materials warned that there could be no assurances that prices
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