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Moreover, petitioners did not adequately explain how the so-
called oil crisis 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 for new resin pellets would remain at
their then current level. One of respondent's experts, Steven
Grossman, explained that the price of plastics materials is not
directly proportional to the price of oil. In his report, he
stated that less than 10 percent of crude oil is utilized for
making plastics materials and that studies have shown that "a
300% increase in crude oil prices results in only a 30 to 40%
increase in the cost of plastics products." Furthermore, during
1980 and 1981, in addition to the media coverage of the so-called
oil crisis, there was "extensive continuing press coverage of
questionable tax shelter plans." Zmuda v. Commissioner, 731 F.2d
1417, 1422 (9th Cir. 1984), affg. 79 T.C. 714 (1982).
Petitioners' reliance on Krause v. Commissioner, 99 T.C. 132
(1992), affd. sub nom. Hildebrand v. Commissioner, 28 F.3d 1024
(10th Cir. 1994), is misplaced. The facts in Krause v.
Commissioner, supra, are distinctly different from the facts of
these cases. In Krause v. Commissioner, supra, the taxpayers
invested in limited partnerships whose investment objectives
concerned enhanced oil recovery (EOR) technology. The Krause
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