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Sentinel EPS recycler could recycle expanded polystyrene into a
densified, devolatized polystyrene and would simultaneously
preserve the physical properties of polystyrene. Petitioner
personally observed a Sentinel EPS recycler in operation.
Petitioner retained Ulanoff and Burstein to issue marketing
and technical opinions, respectively, regarding the Sentinel EPS
recyclers.
Petitioner also retained the law firm of Boylan & Evans to
issue a legal opinion regarding the Sentinel EPS recyclers.
William A. Boylan (Boylan) and John D. Evans (Evans) were
formerly partners at WMDI before leaving in 1982 and forming
their own law firm. Boylan & Evans issued a legal opinion on
December 1, 1982.
There is no evidence in the record that any member of Boylan
& Evans had any expertise in the plastics industry or retained
plastic experts to assist the firm in evaluating petitioner's
purchase of the Sentinel EPS recyclers.
Petitioner consulted with Miller regarding the details of
petitioner's purchase of the Sentinel EPS recyclers. On
September 17, 1982, Miller organized Resin Recyclers, Inc. (RRI),
an S corporation wholly owned by petitioner, which was
specifically created for the Sentinel EPS recycler transactions.
RRI was designed to be a joint venturer with PI and
partnerships investing in the Sentinel EPS recyclers. In theory,
RRI was to place Sentinel EPS recyclers with end-users, and to
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