- 29 - in connection with the transactions were reasonable in light of his experience and the nature of the investment or business. See Henry Schwartz Corp. v. Commissioner, 60 T.C. 728, 740 (1973). When considering the negligence addition to tax, we evaluate the particular facts of each case, judging the relative sophistication of the taxpayers, as well as the manner in which they approached their investment. McPike v. Commissioner, T.C. Memo. 1996-46. Compare Spears v. Commissioner, T.C. Memo. 1996- 341 with Zidanich v. Commissioner, T.C. Memo. 1995-382. Petitioners maintain that they were reasonable in claiming deductions and credits with respect to the Partnerships. They argue that they expected an economic profit in light of the so- called oil crisis in the United States in 1981 and that they reasonably relied upon Alter and Feinstein as qualified advisers on this matter. 1. The So-Called Oil Crisis Petitioners in their posttrial briefs each contend that they reasonably expected to make an economic profit from the Partnerships because plastic is an oil derivative and the United States was experiencing a so-called oil crisis during the year 1981. Based upon our review of the records, we find petitioners' claims unconvincing, regardless of the so-called oil crisis. Moreover, testimony by one of respondent's experts establishes that the oil pricing changes during the late 1970's and early 1980's did not justify petitioners' claiming excessive investmentPage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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