- 31 -                                         
          Accordingly, the tax opinion letters expressly indicate that                
          prospective investors such as petitioners were not to rely upon             
          the tax opinion letter.  See Collins v. Commissioner, supra.  The           
          limited, technical opinion of tax counsel expressed in these                
          letters was not designed as advice upon which taxpayers might               
          rely, and the opinion of counsel itself so states.  As                      
          sophisticated attorneys and investors, Friedman and Alter knew or           
          should have known that the opinion letter had a limited function,           
          that the caveats and warnings in the letter were to be taken                
          seriously, and certainly that they could not rely upon the                  
          opinion letter without full investigation of the economic and               
          other factual assumptions upon which it explicitly was based.               
               2.  The So-Called Oil Crisis                                           
               Petitioners each testified that they reasonably expected to            
          make an economic profit from the Partnership transactions because           
          plastic is an oil derivative and the United States was                      
          experiencing a so-called oil crisis during the year 1981.  Based            
          upon our review of the records, we find petitioners' claims                 
          unconvincing, regardless of the so-called oil crisis.  Moreover,            
          testimony by one of respondent's experts establishes that the oil           
          pricing changes during the late 1970's and early 1980's did not             
          justify petitioners' claiming excessive investment credits and              
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