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operation once owned by petitioner's family. During these years
petitioner was also actively involved in running several
privately held corporations.
In addition to gaining experience as a CEO and business
executive, petitioner learned about plastic commodities, plastic
resins, and petrochemicals. Petitioner has purchased millions of
dollars of plastic processing machinery and, except for the
recyclers that petitioner purchased in 1981 and 1982, has never
paid more than several hundred thousand dollars for an individual
piece of equipment. Tax credits and benefits were important
considerations to petitioner in purchasing plastics-processing
equipment.
Some of the companies in which petitioner was actively
involved, Gotham Corp. in particular, experienced problems with
the disposal of expanded polystyrene scrap. Expanded polystyrene
is a highly porous form of polymer that can be produced in
various grades or densities. The density of expanded polystyrene
varies inversely with the volume of trapped gases within the
polymer. The gases trapped in the polymer are volatile. Gotham
Corp. generated large quantities of expanded polystyrene that
were bulky and volatile. Local landfills and dumps became
unwilling to accept the expanded polystyrene scrap generated by
Gotham Corp., thereby creating disposal problems for petitioner.
In the mid-1970's petitioner became acquainted with Elliot
I. Miller (Miller), a practicing attorney experienced in tax
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