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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. Indeed, while Cote testified
that he saw a correlation between resin pellets, an oil-based
product, and the price of oil, he could not "recall ever making a
direct connection between those two". 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
from the facts of these cases. In the Krause case, the taxpayers
invested in limited partnerships whose investment objectives
concerned enhanced oil recovery (EOR) technology. The Krause
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