Peter and Ursula Reimann, et al. - Page 19

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          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 not           



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