- 15 - Petitioner testified that before petitioner invested in Northeast, Grant told him that he had investigated the Sentinel EPE recyclers and that the recycling machine "was to the best of his knowledge truly unique." Petitioner testified that, given Grant's statement, he thought the question of the price of a comparable machine was academic. Petitioner argues that there should have been no comparable machine. In fact, there were at least four other plastics recycling machines available during 1981, ranging in price from $20,000 to $200,000: Foremost Densilator, Nelmor/Weiss Densification System (Regenolux), Buss- Condux Plastcompactor, and Cumberland Granulator. See Provizer v. Commissioner, supra. Petitioner also contacted Roberts. Petitioner testified that because Grant and Roberts shared office space and engaged in business transactions together, petitioner presumed that Grant considered Roberts to be a person of suitable moral character and business competence. Petitioner also stated that he asked Roberts whether he expected the IRS to question the price of the recyclers for the tax credits. According to petitioner, Roberts told him he would not be surprised if the IRS questioned the purported price of the Sentinel EPE recyclers, but that he believed there would be a compromise reducing the amount of valuation by less than 20 percent. Petitioner accepted Roberts' statement without further question.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011