- 25 - sophistication of the taxpayers, as well as the manner in which they approached their investment. McPike v. Commissioner, T.C. Memo. 1996-46. Compare Spears v. Commissioner, T.C. Memo. 1996- 341 with Zidanich v. Commissioner, T.C. Memo. 1995-382. Petitioner maintains that he and his wife were reasonable in claiming deductions and credits with respect to the Partnerships. He claims that he (1) carefully read the SAB Recovery offering memorandum; (2) intended and reasonably expected to make an economic profit from the Partnerships in light of the so-called oil crisis in the United States in 1981 and 1982; and (3) reasonably relied upon Tucker as a qualified adviser on this matter. 1. The Private Offering Memoranda Petitioner testified that he relied in part upon the SAB Recovery offering memorandum. He claimed that he and his wife spent several consecutive evenings carefully reading it. Petitioner did not indicate how much time, if any, he spent reviewing the SAB Reclamation offering memorandum. Each of the offering memoranda highlighted a number of tax risk factors and 12 business risk factors, including the following: (1) The Partnerships had no operating history; (2) management of the Partnerships' business was dependent upon the general partner, who had no experience in marketing recycling equipment and who was required to devote only such time to the Partnerships as such general partner deemed necessary; (3) thePage: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
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