David and Shirley Singer - Page 32

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          were reasonable in claiming credits on their 1981 Federal income            
          tax return based upon each recycler's having a value of                     
          $1,162,666.  In support of this position, petitioners submitted             
          into evidence preliminary reports prepared for respondent by                
          Ernest D. Carmagnola (Carmagnola), the president of Professional            
          Plastic Associates.  Carmagnola had 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             




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