Donald N. and Rosemarie F. Merino - Page 29

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          been retained by the IRS in 1984 to evaluate the Sentinel EPE and           
          EPS recyclers in light of what he described as "the fantastic               
          values placed on the [recyclers] by the owners."  Based on                  
          limited information available to him at that time, Carmagnola               
          preliminarily estimated that the value of the Sentinel EPE                  
          recycler was $250,000.  However, after additional information               
          became available to him, Carmagnola concluded in a signed                   
          affidavit, dated March 16, 1993, that the machines actually had a           
          fair market value of not more than $50,000 each in the fall of              
          1981.                                                                       
               We accord no weight to the Carmagnola reports submitted by             
          petitioners.  The projected valuations therein were based on                
          inadequate information, research, and investigation, and were               
          subsequently rejected and discredited by their author.  In one              
          preliminary report, Carmagnola states that he has "a serious                
          concern of actual profit" of a Sentinel EPE recycler and that to            
          determine whether the machines actually could be profitable, he             
          required additional information from PI.  Carmagnola also                   
          indicates that in preparing the report, he did not have                     
          information available concerning research and development costs             
          of the machines and that he estimated those costs in his                    
          valuations of the machines.                                                 
               Respondent rejected the Carmagnola reports and considered              
          them unsatisfactory for any purpose, and there is no indication             
          in the record that respondent used them as a basis for any                  




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