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          EPS recyclers.  It is peculiar that, although petitioner had yet            
          to make a profit from his purchase of a Sentinel EPE recycler, he           
          nevertheless continued to purchase additional, more expensive               
          recyclers, more than doubling his investment.                               
               Second, petitioner has presented no evidence that he made a            
          serious effort to monitor his investment in the Sentinel                    
          recyclers.  At trial, petitioner could not recall the names of              
          the companies with which he placed his machines.                            
               Third, petitioner did not know the whereabouts of his                  
          recyclers at the time of trial, stating that he had "abandoned"             
          the recyclers because PI failed to maintain them.  Petitioner               
          testified that he did not profit from his recyclers because of              
          continual repair problems and PI's failure to maintain and repair           
          the machines as agreed.  It would seem to us that a $4,662,667              
          investment would warrant repair and maintenance, even if such               
          repairs were not performed by PI as initially agreed.                       
               Taking all of the above factors into consideration, we think           
          it is more likely than not that petitioner purchased the Sentinel           
          recyclers in an effort to generate tax benefits rather than to              
          make a profit.9                                                             
               9 Here we are reminded that petitioner learned about the               
          Sentinel recyclers after contacting Miller in an effort to locate           
          equipment that would enable petitioner to take advantage of tax             
          benefits.                                                                   
               Although not directly germane to our conclusion set forth in           
          the text, supra, we nevertheless note that petitioner has                   
                                                             (continued...)           
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