Oreland A. and Lucille S. Thornsjo - Page 30




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          media during the late 1970’s and early 1980’s, petitioners have             
          failed to demonstrate that the so-called energy crisis provided a           
          reasonable basis for them to invest in Hamilton.                            
               In addition, the taxpayers in Krause were either experienced           
          in or investigated the oil industry and EOR specifically.  One of           
          the taxpayers in Krause undertook a significant investigation of            
          the proposed investment, including researching EOR.  The other              
          taxpayer was a geological and mining engineer who hired an                  
          independent expert to review the offering materials.  See id. at            
          166.  In the present cases, petitioners did not have any                    
          experience or education in plastics recycling.  Moreover, Woolf             
          and Furlong did not undertake any independent investigation of              
          the recyclers, and Thornsjo’s cursory inquiries did not amount to           
          a reasonably thorough investigation, particularly for a person of           
          his stature and background.                                                 
               Petitioners next argue that they were not negligent because            
          they continued to monitor their investments in Hamilton.  To                
          support this argument, petitioners assert that Schluter read a              
          WSJ article regarding Hamilton, that Schluter read a letter from            
          Hamilton’s TMP regarding the WSJ article, that they contacted               
          Schluter with regard to the WSJ article, that they contacted                
          Schluter with regard to IRS correspondence, and that Schluter               
          monitored and discussed with them progress reports regarding                
          Hamilton’s IRS audit.  Contrary to petitioners’ arguments, these            






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