- 30 - Petitioners each contend that they were reasonable in claiming deductions and investment credits with respect to their investments in the Partnerships. In support of such contentions, petitioners each argue, in general terms: (1) That claiming the deductions and credits with respect to the Partnerships was reasonable in light of the so-called oil crisis during the years in issue and (2) that they reasonably relied upon the offering materials and a qualified adviser. In the cases before us, expert testimony by report 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. Also, we are unconvinced by the claim of these highly sophisticated, able, and successful investors that they acted reasonably in failing to inquire about their investment and simply relying on the offering circulars and on Becker, despite warnings in the offering circulars and explanations by Becker about the limitations of his investigation. In each case these taxpayers knew or should have known better. 1. The So-Called Oil CrisisPage: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
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