Stuart A. and Harriet J. Gollin, et al. - Page 42

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          manager of Equitable Bag Co., a manufacturer of paper and plastic           
          bags.  Becker spoke to Canno about the recyclers and PI, but did            
          not hire or pay him for any advice.  Canno did not visit the PI             
          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.  Becker 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; instead, several machines capable of           
          densifying low density materials were already on the market.                
          Other plastics recycling machines available during 1982 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              




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