Bernice M. and Stanley M. Ulanoff - Page 10




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          energy credits in the aggregate amount of $82,639, plus                     
          deductions in the amount of $40,376.  The private offering                  
          memorandum for Taylor stated that the projected tax benefits for            
          the initial year of investment for an investor contributing                 
          $50,000 would be investment credits and energy credits in the               
          aggregate amount of $81,529, plus deductions in the amount of               
          $39,988.                                                                    
               The offering memoranda represented that the Sentinel                   
          recyclers were unique machines.  However, they were not.  Several           
          machines capable of densifying low density materials were already           
          on the market in 1981 and 1982.  Other plastics recycling                   
          machines available at that time ranged in price from $20,000 to             
          $200,000, including the Foremost "Densilator", the Nelmor/Weiss             
          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.                                                           
          D.   Expert Testimony                                                       
               The parties did not agree on the value of either the                   
          Sentinel EPE or EPS recyclers, and petitioner did not stipulate             
          to be bound by the value of the Sentinel EPE recyclers that we              
          found in Provizer v. Commissioner, supra, or the value of the EPS           
          recyclers that we found in Gottsegen v. Commissioner, T.C. Memo.            
          1997-314.                                                                   





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