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Densification System (Regenolux), the Buss-Condux Plastcompactor,
and the Cumberland Granulator. See Provizer v. Commissioner,
T.C. Memo. 1992-177, and the discussion regarding expert
testimony, infra. At the time of the closing of the Clearwater
transactions on December 21, 1981, there was no established
market for leasing or operating the Sentinel EPE recyclers.
D. Expert Testimony
Although petitioners conceded the overvaluation of the
Sentinel EPE recyclers, the parties did not agree on the
recyclers' value, and petitioners did not stipulate to be bound
by the value of the recyclers that we found in Provizer.
At trial, petitioners did not offer expert testimony
regarding the value of the Sentinel EPE recyclers. In contrast,
respondent offered expert testimony from Steven Grossman
(Grossman) and Richard S. Lindstrom (Lindstrom).
1. Grossman
Grossman is a professor in the Plastics Engineering
Department at the University of Massachusetts at Lowell. He has
a bachelor of science degree in chemistry from the University of
Connecticut and a doctorate in polymer science and engineering
from the University of Massachusetts. He also has more than 15
years of experience in the plastics industry, including more than
4 years of experience as a research and development scientist at
the Upjohn Company in its Polymer Research Group.
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