William and Joan Spears - Page 30

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               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 Crisis                                           











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