Mark Friedman - Page 51

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          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.                                                      







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