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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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