Allan J. and Brenda Becker - Page 35

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          Petitioner defined "state-of-the-art" as "highly-electronic,                
          rather than a lot of mechanical parts--electrical parts, where              
          you can just punch buttons in to the work, rather than people               
          physically moving levers and changing things."  However, the                
          Sentinel recyclers were not "state-of-the-art" by any definition.           
          The Sentinel EPE recycler was incapable of recycling expanded               
          polyethylene by itself, and had to be used in connection with               
          extruders and pelletizers.  In contrast, the Nelmor Regenolux,              
          which was available in 1981 for $38,000, was fully capable of               
          recycling expanded polyethylene or expanded polystyrene and                 
          worked better than either the Sentinel EPE or EPS recycler.                 
               Petitioner testified that he invested in SAB Recovery based            
          on a conversation with his father, and Becker's "* * * pushing me           
          into it".  As for SAB Recycling, petitioner testified that he               
          decided to invest in that partnership after Becker purportedly              
          told him that SAB Recovery had done well, and again speaking with           
          his father.  However, petitioner failed to explain how SAB                  
          Recovery had done well, except for generating claims to tax                 
          benefits.  SAB Recovery received no cash receipts during 1982,              
          and to the extent that the Sentinel EPE recyclers had been placed           
          with end-users, they were placed with end-users that did not have           
          enough scrap ever to pay off the notes on the machines.                     
               Becker certainly recognized that the purported value of the            
          Sentinel EPE recycler generated the deductions and credits in               
          this case.  Becker explained the tax benefits to petitioner, and            




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