John Sann and Marianne Sann, et al. - Page 47

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               2.  The So-Called Oil Crisis                                           
               Petitioners testified that they reasonably expected to make            
          an economic profit from the Partnership transactions because                
          plastic is an oil derivative and the United States was                      
          experiencing a so-called oil crisis when they invested in the               
          Partnerships.  Based upon our review of the records, we find                
          petitioners' claims unconvincing, regardless of the so-called oil           
          crisis.  Moreover, persuasive 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 credits and purported losses based on vastly           
          exaggerated valuations of recycling machinery.                              
               Petitioners did not educate themselves in, or personally               
          investigate, the business aspects of the Plastics Recycling                 
          transactions.  Nor did they attempt to resolve the numerous                 
          business-related caveats and warnings in the offering memoranda.            
          Petitioners purport to have relied on Maxfield, but Maxfield made           
          it clear to all concerned that he was not an investment analyst             
          and that he had no training to decide whether the price of oil              
          was going to increase or decrease.  Maxfield also told the                  
          members of Sann & Howe that he considered the relationship                  
          between the potential value of the recycled pellets and the price           
          of oil to be a negative aspect of the proposed investment.  In              
          addition, petitioners received progress reports with respect to             






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