- 51 - that the machines actually had a fair market value of not more than $50,000 each in the fall of 1981.13 We accord no weight to the Carmagnola reports submitted by petitioners. The projected valuations therein were based on inadequate information, research, and investigation, and were subsequently rejected and discredited by their author. In one preliminary report, Carmagnola states that he has "a serious concern of actual profit" 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. Respondent rejected the Carmagnola 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, counsel 13 The parties stipulated as to the authenticity of the Carmagnola reports, but respondent objected on grounds of relevance, materiality and hearsay. Since these reports have been included in the record in many other plastics recycling cases, we admitted them into evidence with the caveat that if Mr. Carmagnola was not called to testify, we expected to give minimal weight to the reports.Page: Previous 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 Next
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