- 34 -
including researching EOR technology. The other taxpayer was a
geological and mining engineer whose work included research of
oil recovery methods and who hired an independent geologic
engineer to review the offering materials. Id. at 166. In the
present cases, none of petitioners has any education or work
experience with respect to plastics or plastics recycling.
Petitioners did not independently investigate the Sentinel EPE
recyclers, nor did they hire an expert in plastics to evaluate
the Partnership transactions. Petitioners' arguments with
respect to the Krause case are inapplicable here.
Petitioners' reliance on Rousseau v. United States, supra,
is similarly misplaced. In Rousseau, the property underlying the
investment, ethanol producing equipment, was widely considered at
that time to be a viable fuel alternative to oil and its
potential for profit was apparent. In addition, the taxpayer
therein conducted an independent investigation of the investment
and researched the market for the sale of ethanol in the United
States. In contrast, as we noted in distinguishing the Krause
case, there is no showing in these records that the so-called oil
crisis would provide a reasonable basis for petitioners'
investing in the polyethylene recyclers here in question.
Petitioners did not independently investigate the Sentinel EPE
recyclers or hire an expert in plastics to evaluate the
Partnership transactions. The facts of petitioners' cases are
distinctly different from the Rousseau case. Accordingly, we do
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