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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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