Robert Gottsegen - Page 12

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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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