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Federal Government adopted specific programs to aid research and
development of EOR technology. Id. at 135-136. In holding that
the taxpayers in the Krause case were not liable for the
negligence additions to tax, this Court noted that one of the
Government's expert witnesses acknowledged that "investors may
have been significantly and reasonably influenced by the energy
price hysteria that existed in the late 1970's and early 1980's
to invest in EOR technology." Id. at 177. In the present cases,
however, as explained by respondent's expert Steven Grossman,
supra, the price of plastics materials was not directly
proportional to the price of oil, and there is no persuasive
evidence that the so-called oil crisis had a substantial bearing
on petitioners' decision to invest. While EOR was, according to
our Krause opinion, in the forefront of national policy and the
media during the late 1970's and 1980's, there is no showing in
these records that the so-called energy crisis would provide a
reasonable basis for petitioners' investing in recycling of
polyethylene, particularly in the machinery here in question.
Moreover, the taxpayers in the Krause opinion were
experienced in or investigated the oil industry and EOR
technology specifically. One of the taxpayers in Krause v.
Commissioner, supra, undertook significant investigation of the
proposed investment including researching EOR technology. The
other taxpayer was a geological and mining engineer whose work
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