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plant in Hyannis, see or test a Sentinel EPE recycler, or see or
test any of the output from a Sentinel EPE recycler or the
recycled resin pellets after they were further processed by PI.
According to Becker, Canno endorsed the Partnership transactions
after reviewing the offering materials. Asked at trial if Canno
had done any type of comparables analysis, Becker replied, "I
don't know what Mr. Canno did."
Becker visited the PI plant in Hyannis, toured the facility,
viewed a Sentinel EPE recycler in operation, and saw products
that were produced from recycled plastic. He claims that during
his visit he was told that the recycler was unique and that it
was the only machine of its type. In fact, the Sentinel EPE
recycler was not unique, and information published prior to the
Sentinel EPE recycling transactions indicated that several
machines capable of densifying low density materials already were
on the market. Other plastics recycling machines available
during 1981 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
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