- 21 - Memo. 1996-46. Compare Spears v. Commissioner, T.C. Memo. 1996- 341 with Zidanich v. Commissioner, T.C. Memo. 1995-382. Petitioners contend that they were reasonable in claiming a loss deduction and investment tax and business energy credits with respect to Plymouth. Petitioner maintains that he expected an economic profit in light of the so-called oil crisis in the United States in 1981, and that he reasonably relied upon Bach as a qualified adviser on this matter. 1. The So-Called Oil Crisis Petitioner claims that he reasonably expected to make an economic profit because plastic is an oil derivative and the United States was experiencing a so-called oil crisis when he invested in Plymouth. Based upon our review of the record, we find petitioner's claim 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 credits and purported losses based on vastly exaggerated valuations of recycling machinery. Petitioner testified that he "was told by Marty [Bach] or Abe Bramnick that the potential of the investment is great because oil is going crazy and this thing was something". Bramnick did not testify at the trial of this case, and Bach could not recall the substance of his communications with petitioner. Petitioner did not read the Plymouth offeringPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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