Robert Gottsegen - Page 10

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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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