Philippe and Nadine Grelsamer - Page 28

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               When petitioners invested in the partnerships, they had no             
          education or experience in plastics materials or plastics                   
          recycling, nor had any of them seen a Sentinel recycler.  In each           
          of these consolidated cases, petitioners contend that they were             
          reasonable in claiming deductions and credits with respect to 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 in the United States in 1981 and 1982; and             
          (2) that they reasonably relied upon the offering materials and             
          qualified advisers, specifically Becker, Green, and their tax               
          return preparers.                                                           
               1.  The So-Called Oil Crisis                                           
               Petitioners maintain that they reasonably expected to make             
          an economic profit from the Partnership transactions, in                    
          particular because plastic is an oil derivative and the United              
          States was experiencing a so-called oil crisis during the years             
          1981 and 1982.  In support of this argument, petitioners cite               
          Krause v. Commissioner, 99 T.C. 132 (1992), affd. sub nom.                  
          Hildebrand v. Commissioner, 28 F.3d 1024 (10th Cir. 1994).                  
               Petitioners' contention that they reasonably expected an               
          economic profit from the Partnership transactions is                        
          unconvincing, regardless of the so-called oil crisis.                       
          Petitioners made no effort to resolve the caveats and warnings              






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