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The record reveals little information about Ulanoff and
Burstein other than the fact that both were investors in Sentinel
recyclers. There is no indication that either Ulanoff or
Burstein had any expertise in the plastics industry or that they
retained a plastics expert to help them analyze petitioner's
purchase of the Sentinel EPE recycler.
Petitioner also retained the law firm of Windells, Marx,
Davis & Ives (WMDI) to issue a legal opinion. On October 15,
1981, WMDI issued a legal opinion to petitioner. The opinion was
not introduced into evidence at the trial of the present cases.
Petitioner apparently retained WMDI because WMDI's tax
department, headed by John Y. Taggart (Taggart), was preparing
the legal opinion for the closings for all of the Sentinel EPE
recyclers manufactured by PI in 1981. Taggart, in addition to
being the head of the WMDI's tax department, was an adjunct
professor at New York University and had previously been employed
by the U.S. Department of the Treasury. Taggart also owned a
6.66-percent interest in a second-tier Plastics Recycling
partnership.
There is no evidence in the record that Taggart or any other
member of WMDI had any expertise in the plastics industry.
Further, there is no evidence in the record that WMDI retained
experts in the plastics industry to help the firm analyze and
assess petitioner's purchase of the Sentinel EPE recycler.
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