- 10 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011