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distinctly different from the facts of this case. In the Krause
case, the taxpayers invested in limited partnerships whose
investment objectives concerned enhanced oil recovery (EOR)
technology. The Krause opinion states that during the late
1970's and early 1980's, the Federal Government adopted specific
programs to aid research and development of EOR technology. Id.
at 135-136. In holding that the taxpayers in the Krause case
were not liable for the negligence additions to tax, this Court
noted that one of the Government's expert witnesses acknowledged
that "investors may have been significantly and reasonably
influenced by the energy price hysteria that existed in the late
1970s and early 1980s to invest in EOR technology." Id. at 177.
In the present case, however, as explained by respondent's expert
Steven Grossman, the price of plastics materials was not directly
proportional to the price of oil, and there is no persuasive
evidence that the so-called oil crisis had a substantial bearing
on petitioners' decision 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
the record 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 opinion were
experienced in or investigated the oil industry and EOR
technology specifically. One of the taxpayers in the Krause case
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