- 35 - 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, andPage: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
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