Leon M. and Mary K. Jaroff - Page 32

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          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            




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