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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 investment
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