- 32 -
rely, and the opinion of counsel itself so states.
2. The So-Called Oil Crisis
Petitioner contends that he 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 years 1981 and 1982. Based upon our
review of the record, we find petitioner's contention
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
purported losses based on vastly exaggerated valuations of
recycling machinery.
By 1981 petitioner had approximately 30 years' experience
as, variously, a reporter, bureau correspondent, and editor for
the magazines Life, Time, and Discover. He confirmed at trial
that if he needs information, he knows how to get it. In
addition to utilizing libraries and varying publications,
petitioner noted that "one of the ways that * * * [he] [gets]
information best is to go to experts, * * * generally in the
[fields] of science and technology and medicine." Despite his
research and reporting experience, and the resources available to
him at Time, Inc., petitioner did not educate himself in, or
personally investigate, the plastics recycling transactions; nor
Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 NextLast modified: May 25, 2011