Stuart A. and Harriet J. Gollin, et al. - Page 60

                                       - 60 -- 60 -                                        
          concluded in a signed affidavit, dated March 16, 1993, that the             
          machines actually had a fair market value of not more than                  
          $50,000 each in the Fall of 1981 and 1982.                                  
               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              
          for petitioners in docket Nos. 16922-90 and 19612-90 obtained               
          copies of these reports and urge that they support the                      
          reasonableness of the values reported on the Gollins' and                   
          Fishbachs' returns.  Not surprisingly, counsel in those cases did           
          not call Carmagnola to testify, but preferred instead to rely               






Page:  Previous  50  51  52  53  54  55  56  57  58  59  60  61  62  63  64  65  66  67  68  69  Next

Last modified: May 25, 2011