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Petitioners also argue, in general terms, that they were
reasonable in claiming the deductions and credits related to the
Partnerships because of rising oil prices in the United States in
1981. In support of this argument, petitioners placed into the
record several articles from Modern Plastics and an energy
projections report from the U.S. Department of Energy (DOE), all
published in the years 1980 and 1981. Petitioners also cite
Krause v. Commissioner, 99 T.C. 132 (1992), affd. sub nom.
Hildebrand v. Commissioner, 28 F.3d 1024 (10th Cir. 1994), and
Rousseau v. United States, 91-1 USTC par. 50,252 (E.D. La. 1991).
The articles from Modern Plastics and the report by the DOE
speculated on the price of oil, among other matters. The preface
to the DOE report cautioned about "the tremendous uncertainties
underlying energy projections" and warned "that [their]
projections do not constitute any sort of blueprint for the
future." Reflective of such uncertainties, an April 1980 article
in Modern Plastics contemplated resin price hikes, while a May
1981 article predicted a leveling off of prices, market
disruptions, and an industrywide shakeout. Petitioners do not
purport to have read, or in any way relied upon, the DOE report
or the Modern Plastics articles, and have not otherwise explained
the connection between these speculative materials and their
investments in the Partnerships. Petitioners' vague, general
claims concerning the so-called oil crisis are without merit.
Petitioners' reliance on Krause v. Commissioner, supra, is
misplaced. The facts in the Krause case are distinctly different
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