Robert Gottsegen - Page 38

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          expertise to have made his actions reasonable, he must have                 
          conducted a meaningful investigation into the investment.  For              
          the reasons below, we do not think petitioner conducted such an             
          investigation.                                                              
               There were several factors that should have alerted                    
          petitioner to the fact that the Sentinel recyclers were                     
          overvalued.  The exorbitant cost of the recyclers (i.e.,                    
          $1,162,667 and $1,750,000 for the Sentinel EPE and EPS recyclers,           
          respectively) should have made petitioner question the purchases.           
          Here we are reminded that prior to purchasing the recyclers,                
          petitioner had never paid more than several hundred thousand                
          dollars for plastic processing equipment.  The price of the                 
          Sentinel recyclers should have appeared particularly excessive to           
          petitioner because there was no established market for such                 
          recyclers at the time that petitioner purchased them.                       
               Additionally, respondent's experts identified other machines           
          that were not only functionally equivalent to the Sentinel                  
          recyclers but also significantly less expensive.  Here we recall            
          petitioner's testimony that in determining the value of the                 
          Sentinel EPE recycler he "looked around the industry" and did not           
          discover any machines successfully recycling expanded                       
          polyethylene.  Manufacturers questioned by petitioner allegedly             
          told him that they had "reservations" and "no firm assertions"              
          about recycling polyethylene.  Aside from this testimony,                   
          petitioner offered few details in respect of his investigation              




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