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Petitioners' so-called oil crisis argument has been made in
more than 20 of the Plastics Recycling cases. See, e.g.,
Provizer v. Commissioner, supra; Merino v. Commissioner, T.C.
Memo. 1997-385; Singer v. Commissioner, T.C. Memo. 1997-325; Sann
v. Commissioner, T.C. Memo. 1997-259. We have found this
argument to be unpersuasive in every one of those cases.
Petitioners' argument is no different in any substantive manner,
nor is their argument based on any legal authority not previously
considered in those cases. We will not revisit the oil crisis
argument. We therefore hold that the so-called oil crisis did
not provide a reasonable basis for petitioners to conclude that
the Clearwater investment would be profitable.
B. Reliance on the Private Offering Memorandum
We next address the contention that petitioner reasonably
relied on the Clearwater private offering memorandum, and
specifically on the reports of Burstein and Ulanoff, in making
the Clearwater investment and claiming the tax benefits
therefrom.8
8 Petitioners also claim that petitioner relied on the
advice of Shea & Gould's tax partner, Alan Parker (Parker).
However, petitioners failed to present any evidence in this
regard other than petitioner's own testimony. We do not find
petitioner's self-serving testimony sufficient or particularly
reliable in this regard. See Tokarski v. Commissioner, 87 T.C.
74, 77 (1986); Hawkins v. Commissioner, T.C. Memo. 1993-517,
affd. without published opinion 66 F.3d 325 (6th Cir. 1995).
Regardless, the record does not demonstrate: (1) Whether Parker
(continued...)
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