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determinations in the notice of deficiency. Even so, counsel for
petitioners obtained copies of these reports and urge that they
support the reasonableness of the value reported on petitioners'
1981 return. Not surprisingly, counsel for petitioners did not
call Carmagnola to testify in this case, but preferred instead to
rely solely upon his preliminary ill-founded valuation estimates.
(Carmagnola has not been called to testify in any of the Plastics
Recycling cases before us.) The Carmagnola reports were a part
of the record considered by this Court and reviewed by the Court
of Appeals for the Sixth Circuit in the Provizer case, where we
held the taxpayers negligent. We find in this case, as we have
found previously, that the reports prepared by Carmagnola are
unreliable and of no consequence.
5. The Oil Pricing Argument
Petitioner testified that he reasonably expected to make an
economic profit from Northeast and that speculation regarding
crude oil prices "was the critical factor" in his decision to
invest. He indicated that the price of plastic is directly
proportional to the price of crude oil, and that when he invested
in Northeast, the prevailing opinion in both the public and
private sectors was that, due to the so-called oil crisis, the
price of crude oil was going to increase significantly. As
evidence of such speculation, petitioners placed into the record
several articles from Modern Plastics, dated April 1980, May
1981, and August 1981, and an energy projections report from the
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