- 19 - that one of the components of polyethylene was oil and that recycling was good for the environment. Philip Yarnell claims he understood that there was no competition for the Sentinel EPE recycler. In fact, information published prior to the Plastics Recycling transactions indicated that several similar machines already were on the market. These included at least four other plastics recycling machines available during 1981, ranging in price from $20,000 to $200,000: Foremost Densilator, Nelmor/Weiss Densification System (Regenolux), Buss-Condux Plastcompactor, and Cumberland Granulators. See Provizer v. Commissioner, T.C. Memo. 1992-177. Philip Yarnell purportedly did not know whether Bachmann had any expertise in engineering or plastics. Marvin Yarnell, on the other hand, knew that Bachmann did not have any such expertise. Neither Marvin nor Philip Yarnell asked Bachmann to consult anyone with expertise in the field of plastics or plastics recycling. Both were aware that the amount of the tax benefits flowing from Plymouth exceeded their respective investments in the partnership. Marvin and Philip Yarnell did not independently investigate Plymouth or any of the representations made in the offering memorandum. The Yarnells did not have any education or work experience in plastics recycling or plastics materials. OPINION In Provizer v. Commissioner, T.C. Memo. 1992-177, a test case for the Plastics Recycling group of cases, this Court (1) found that each Sentinel EPE recycler had a fair market value notPage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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