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into the Sentinel EPE recyclers. See Wichita Terminal Elevator
Co. v. Commissioner, 6 T.C. 1158, 1165 (1946), affd. 162 F.2d 513
(10th Cir. 1947).
Petitioner testified that he examined the Japan Repro
recycler, but that, based on his observations, that machine did
not produce a "commercially acceptable" product. However,
petitioner presented no evidence, other than his own conclusory
and self-serving testimony, regarding what he viewed as the
differences between the Japan Repro recycler and the Sentinel EPS
recycler.
Other than the Japan Repro recycler, petitioner could not
recall the name or model of any other recycler that he allegedly
considered before purchasing the Sentinel EPS recyclers. There
is no indication in the record that petitioner surveyed the then
current literature regarding recyclers in order to identify
comparable recyclers and to determine the value of the Sentinel
EPS recycler. Indeed, information regarding comparable, less
expensive recyclers was widely available.
We think that if a potential purchaser, especially one as
technologically sophisticated as petitioner, had conducted a
meaningful investigation into the Sentinel recyclers, such
potential purchaser would have learned that comparable, less
expensive equipment existed and that the Sentinel recyclers were
overvalued. Thus, we find that although petitioner may have been
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