Allan J. and Brenda Becker - Page 30

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          was the only machine of its type.  In fact, the Sentinel EPE                
          recycler was not unique; instead, several machines capable of               
          densifying low density materials were already on the market.                
          Other plastics recycling machines available during 1981 and 1982            
          ranged in price from $20,000 to $200,000, including the Foremost            
          Densilator, Nelmor/Weiss Densification System (Regenolux), Buss-            
          Condux Plastcompactor, and Cumberland Granulator.  See Provizer             
          v. Commissioner, T.C. Memo. 1992-177.                                       
               Becker was also told that PI had put an enormous amount of             
          research and development--10 to 12 years' worth--into the                   
          creation and production of the Sentinel EPE recycler.  When he              
          asked to see the cost records for some kind of independent                  
          verification, however, his request was denied.  Becker was                  
          informed that such information was proprietary and secret, and              
          that he would just have to take PI's representations as true.               
          Although PI claimed that all of its information was a trade                 
          secret, and that it never obtained patents on any of its                    
          machines, PI had in fact obtained numerous patents prior to the             
          recycling transactions, and had also applied for a trademark for            
          the Sentinel recyclers.  Becker decided to accept PI's                      
          representations after speaking with Miller (the corporate counsel           
          to PI), Canno (who had never been to PI's plant or seen a                   
          Sentinel EPE recycler), and a surrogate judge from Rhode Island             
          who did business in the Boston/Cape Cod area (and who had no                
          expertise in engineering or plastics materials).  Becker                    




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