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               Grossman testified that, in 1982, equipment comparable to              
          the Sentinel EPS recycler was "widely available" and                        
          significantly less expensive.  Grossman examined a Sentinel EPS             
          recycler and a Japan Repro recycler and determined that the                 
          mechanical construction of the two machines was "nearly                     
          identical".  Grossman further concluded that the recycled                   
          polystyrene produced by these machines would also be identical.             
          Grossman added that because of the existence of functionally                
          equivalent machines, the Sentinel EPS recycler did not add new              
          technology to the field of recycling and could not therefore                
          justify the "one-of-a-kind" price tag that it carried.                      
               Grossman did not specifically value the Sentinel EPS                   
          Recycler.  However, Grossman concluded that recycling equipment             
          that achieved the same result as the Sentinel EPS recycler sold             
          for about $50,000 during the relevant period.                               
               Lindstrom based his valuation on a comparison between the              
          Sentinel EPS recycler and other commercially available machines.            
          Lindstrom estimated the market value of the Sentinel EPS recycler           
          at approximately $25,000 and estimated the manufacturing cost to            
          be in the range of $20,000.                                                 
               Although petitioner declined to stipulate to the value of              
          the Sentinel EPS recyclers at issue in these cases, he failed to            
          present any evidence by way of expert testimony that rebutted               
          respondent's experts.  Rather than present expert testimony,                
          petitioner, on cross-examination, challenged the findings of                
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