- 45 -
88 T.C. at 1131, rejecting claims to reliance on an adviser where
there is no showing that relevant advice was given.
Alter also recalled speaking to Winer. He thought he
remembered that Winer had indicated that end-users had been
scheduled for the machines, but that Winer did not name the end-
users. Alter did not mention having any other conversations with
Winer. Also like Feinstein, Alter accepted at face value all of
the representations made in the offering memorandum. At trial,
he was asked what made the Sentinel EPE recycler unique. He
replied:
I believe the representation was that they had a
special fluid cooling process that was not available
elsewhere. They made the representations that it had a
dual set of blades, I believe, rotary blades, exterior
rotary blade[s] as well as the interior blades, that
would crush the plastic material more effectively.
In Provizer v. Commissioner, T.C. Memo. 1992-177, we found that
PI's vice president of manufacturing and a developer of PI's
prototype recycler, William Strlzelewicz,
explained that the coolant used in the process was
plain water and not some "trade secret" chemical
compound. End-users stated that a usual method by
which the water might be "injected" was for a factory
worker to dump it on the heated material. * * *
Among the recycler's component parts were replaceable rotating
and stationary cutting blades.
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