Philippe and Nadine Grelsamer - Page 31

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          ventures, we find that petitioners' claims that they reasonably             
          expected an economic profit from the Partnership transactions are           
          incredible, even taking into consideration the so-called oil                
          crisis.                                                                     
               Moreover, petitioners did not 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, supra, and            
          Rousseau v. United States, 71A AFTR 2d 93-4294, 91-1 USTC par.              
          50,252 (E.D. La. 1991), is misplaced.  The facts in Krause v.               
          Commissioner, supra, are distinctly different from the facts of             






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