Leon and Belle Atkind - Page 7

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            the Sentinel EPE recyclers considered in this case are the same                             
            type of machines considered in Provizer.  The fair market value                             
            of a Sentinel EPE recycler in 1981 was not in excess of $50,000.                            
                  PI allegedly sublicensed the recyclers to entities that                               
            would use them to recycle plastic scrap.  The sublicense                                    
            agreements provided that the end-users would transfer to PI 100                             
            percent of the recycled scrap in exchange for a payment from FMEC                           
            Corp. based on the quality and amount of recycled scrap.                                    
                  Petitioner is a sophisticated and very successful                                     
            businessman, entrepreneur, and investor.  After graduating from                             
            high school, petitioner attended Patterson Junior College for 1                             
            year, and then the City College of New York for approximately 3                             
            years at night.  Petitioner pursued a major in philosophy and                               
            received 2 years' worth of credits for the night classes.                                   
            Petitioner started working at age 9, delivering newspapers out of                           
            his father's general store.  Petitioner later employed others to                            
            deliver newspapers and also sold food and merchandise from his                              
            father's general store to his newspaper customers.  Petitioner                              
            continued his newspaper delivery and merchandising business until                           
            he married at age 18.  Then he started a business selling hosiery                           
            by telephone.                                                                               
                  Petitioner prospered in the hosiery telemarketing business                            
            and soon began manufacturing hosiery as well.  That business was                            
            expanded to include manufacturing knitwear, as well as hosiery.                             
            Eventually, this business involved importing, manufacturing, and                            
            selling on a national basis.  In time, petitioner sold that                                 

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