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Lindstrom's statements of his opinion and the basis for it
were reasonable and persuasive, and we rely heavily on his expert
report and testimony in making our finding of fact regarding
valuation.
Grossman did not specifically value the Sentinel EPE
Recycler. However, Grossman concluded that existing technology
was available that provided equivalent capability of recycling
polyethylene. We found Grossman to be an impressive witness, and
we also rely heavily on his expert report and testimony in making
our finding of fact regarding valuation.
We have found as an ultimate fact that the Sentinel EPE
recycler purchased by petitioner in 1981 did not have a fair
market value at that time in excess of $50,000.7 Having so
found, it follows that the adjusted basis of the Sentinel EPE
recycler claimed by petitioner on his returns is by definition
overstated within the meaning of section 6662(e).
2. The Sentinel EPS Recyclers
In order to establish the fair market value of the Sentinel
EPS recyclers, respondent also presented the testimony and expert
witness reports of Grossman and Lindstrom.
7 We observe that our finding is consistent with the finding
in Provizer v. Commissioner, T.C. Memo. 1992-177, affd. without
published opinion 996 F.2d 1216 (6th Cir. 1993), regarding the
fair market value of the Sentinel EPE recycler.
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