- 48 -
v. Commissioner, 864 F.2d 93 (9th Cir. 1989), affg. Patin v.
Commissioner, 88 T.C. 1086 (1987); Lax v. Commissioner, T.C.
Memo. 1994-329; Sacks v. Commissioner, supra; Rogers v.
Commissioner, T.C. Memo. 1990-619; see also Gollin v.
Commissioner, T.C. Memo. 1996-454; Grelsamer v. Commissioner,
T.C. Memo. 1996-399; Zenkel v. Commissioner, T.C. Memo. 1996-398;
Estate of Busch v. Commissioner, T.C. Memo. 1996-342; Spears v.
Commissioner, T.C. Memo. 1996-341, with respect to Becker's
advice in Plastics Recycling cases.
4. Miscellaneous
Petitioners stipulated that the fair market value of a
Sentinel EPE recycler in 1981 was not in excess of $50,000.
Notwithstanding this concession, petitioners contend that they
were reasonable in claiming credits on their Federal income tax
returns based upon each recycler having a value of $1,162,666.
In support of this position, petitioners submitted into evidence
preliminary reports prepared for respondent by Ernest D.
Carmagnola (Carmagnola), the president of Professional Plastic
Associates. Carmagnola had been retained by the IRS in 1984 to
evaluate the Sentinel EPE and EPS recyclers in light of what he
described as "the fantastic values placed on the * * *
[recyclers] by the owners." Based on limited information
available to him at that time, Carmagnola preliminarily estimated
that the value of the Sentinel EPE recycler was $250,000.
However, after additional information became available to him,
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