- 30 - 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, thesePage: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
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