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the market value of the Sentinel EPE recycler did not exceed
$50,000.
Lindstrom observed a Sentinel EPS recycler in operation and
was allowed to inspect the machine closely. Lindstrom estimated
that the manufacturing cost of the Sentinel EPS recycler was
approximately $20,000 and market value of the machine was
approximately $25,000.
E. Petitioner and His Introduction to Plymouth and Taylor
Petitioner acquired a 1.27-percent interest in Plymouth in
1981 for $12,500. Later that year, Plymouth closed its business.
Petitioner acquired a 4.37-percent interest in Taylor in 1982 for
$37,500.
Petitioner holds a Ph.D. in marketing. During the years in
issue, petitioner was employed as a marketing professor, author,
and consultant. At the time of his retirement in 1985,
petitioner had been a professor of marketing for more than 25
years. Petitioner is also an author and has written more than 30
books. In addition, he has produced approximately 150
documentary films.
Petitioner served in World War II and in the U.S. Army
Reserve and has been a consultant to the U.S. Government, the
Postal Service, and certain private entities.
Since childhood, petitioner has been concerned with
protecting natural resources. Petitioner makes every effort to
conserve energy and recycle consumer material.
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