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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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