- 43 -
recycling machines available during 1981 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 asked to
see the cost records for some kind of independent verification,
however, his request was denied. Becker was informed that such
information was proprietary and secret,20 and that he would just
have to take PI's representations as true. Becker decided to
accept PI's representations after speaking with Miller (the
corporate counsel to PI), Canno (who had never been to PI's plant
or seen a Sentinel EPE recycler), and a surrogate judge from
Rhode Island who did business in the Boston-Cape Cod area (and
who had no experience in engineering or plastics materials).
Becker testified that he was allowed to see PI's internal
20 Although PI claimed that all of its information was a trade
secret, and that it never obtained patents on any of its
machines, PI had in fact obtained numerous patents prior to the
recycling transactions and had also applied for a trademark for
the Sentinel recyclers.
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