Donald N. and Rosemarie F. Merino - Page 31

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          DOE, published in July 1981.  The prefatory overview to the DOE             
          report, however, cautioned about "the tremendous uncertainties              
          underlying energy projections" and warned "that [the] projections           
          [in the report] do not constitute any sort of blueprint for the             
          future."  Reflective of such uncertainties, the April 1980 Modern           
          Plastics article contemplated resin price hikes, while the May              
          1981 article predicted a leveling of prices, market disruptions,            
          and an industrywide shakeout.                                               
               In contrast to petitioner's testimony, respondent's expert             
          Grossman explained that the price of plastics materials is not              
          directly proportional to the price of oil.  In his report,                  
          Grossman stated that less than 10 percent of crude oil is                   
          utilized for making plastics materials and that studies have                
          shown that "a 300% increase in crude oil prices results in only a           
          30 to 40% increase in the cost of plastics products."  An even              
          greater disparity was reported in the May 1981 article from                 
          Modern Plastics, which stated:  "A rule-of thumb unproven by                
          cost-accounting but apparent from price history is that with                
          every $1/barrel hike for Saudi marker crude, the per-pound price            
          of ethylene increases by about half a cent."  (Emphasis added.)             
          Indeed, petitioner recalled that during the latter part of 1981             
          and for some months thereafter, while the price of crude oil                
          rose, the price of low density polyethylene actually decreased.             
               Petitioners' reliance on Krause v. Commissioner, 99 T.C. 132           
          (1992), affd. sub nom. Hildebrand v. Commissioner, 28 F.3d 1024             




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