- 54 -                                         
          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,              
          Carmagnola 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             
          Spears.  The projected valuations therein were based on                     
          inadequate information,25 research, and investigation, and were             
          subsequently rejected and discredited by their author.                      
          Respondent likewise rejected the 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, Spears'              
          counsel obtained copies of these reports and urges that they                
          support the reasonableness of the values reported on Spears' 1982           
          joint return.  Not surprisingly, Spears' counsel did not call               
          Carmagnola to testify in these cases,26 but preferred instead to            
          25   In one preliminary report, Carmagnola states that he has "a            
          serious concern of actual profit" from a Sentinel EPE recycler              
          and that to determine whether the machines actually could be                
          profitable, he required additional information from PI.                     
          (Emphasis in original.)  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.            
          26   Carmagnola has not been called to testify in any of the                
          Plastics Recycling cases before us.                                         
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