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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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