Robert D. and Patricia K. Kaliban, et al. - Page 32

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            persuasive evidence that the so-called oil crisis had a                                   
            substantial bearing on petitioners' decisions to invest.  While                           
            EOR was, according to our Krause opinion, in the forefront of                             
            national policy and the media during the late 1970's and 1980's,                          
            there is no showing in these records that the so-called energy                            
            crisis would provide a reasonable basis for petitioners'                                  
            investing in recycling of polyethylene, particularly in the                               
            machinery here in question.                                                               
                  In addition, the taxpayers in the Krause case were                                  
            experienced in or investigated the oil industry and EOR                                   
            technology specifically.  One of the taxpayers in the Krause case                         
            undertook significant investigation of the proposed investment                            
            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, petitioners were not experienced or educated in                            
            plastics recycling, and they did not independently investigate                            
            the Sentinel recyclers or hire an expert in plastics to evaluate                          
            the Partnership transactions.  We consider petitioners' arguments                         
            with respect to the Krause case inapplicable.                                             
                  2.  Petitioners' Purported Reliance on Advisers                                     
                  Petitioners contend that they reasonably relied upon Alter                          
            and Feinstein as qualified advisers on this matter.                                       

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