Thomas E. and Joan A. Bennett - Page 26

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          the Sentinel EPE and EPS recyclers in light of what he described            
          as "the fantastic values placed on the [recyclers] by the                   
          owners."  Based on limited information available to him at that             
          time, Carmagnola preliminarily estimated the value of the                   
          Sentinel EPE recycler to be $250,000.  However, after additional            
          information became available to him, Carmagnola concluded in a              
          signed affidavit, dated March 16, 1993, that the machines                   
          actually had a fair market value of not more than $50,000 each in           
          the fall of 1981 and 1982.                                                  
               We accord no weight to the Carmagnola reports submitted by             
          petitioners.  The projected valuations therein were based on                
          inadequate information,6 research, and investigation, and were              
          subsequently rejected and discredited by their author.                      
          Respondent likewise rejected the reports and considered them                
          unsatisfactory for any purpose; and there is no indication in the           
          records that respondent used them as a basis for any                        
          determinations in the notices of deficiency.  Even so,                      
          petitioners' counsel obtained copies of these reports and urge              
          that they support the reasonableness of the values reported on              
          their returns.  Not surprisingly, petitioners did not call                  

          6    In one preliminary report, Carmagnola states that he has "a            
          serious concern of actual profit-level" of a Sentinel EPE                   
          recycler and that to determine whether the machines actually                
          could be profitable, he required additional information from PI.            
          Carmagnola also indicates that in preparing the report, he did              
          not have information available concerning research and                      
          development costs of the machines and that he estimated those               
          costs in his valuations of the machines.                                    




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