- 26 - supra; Provizer v. Commissioner, supra. The exorbitant cost of the machines, $1,162,667 for the Sentinel EPE recycler and $1,750,000 for the Sentinel EPS recycler, would therefore have only been reasonable if there were other factors to justify such cost. However, other factors indicate that the Sentinel recyclers were highly overvalued. For instance, the Sentinel recyclers were not unique. Respondent's experts identified other machines that were not only functionally equivalent to the Sentinel recyclers but were also significantly less expensive. We have found that information regarding comparable, less expensive recyclers was widely available. If a potential purchaser, especially an individual sophisticated in marketing and research techniques, had conducted a due diligence investigation into the Sentinel recyclers, such potential purchaser should have learned that comparable, less expensive equipment existed and that the Sentinel recyclers were overvalued. Petitioner claims that in determining the value of the recyclers he did not discover any machines capable of performing the functions performed by the Sentinel recyclers. However, there is no indication in the record that petitioner surveyed the then current information regarding recyclers.6 Rather, 6 In his marketing reports, petitioner stated that he independently investigated the value of the recyclers by discussing the matter with "nonrelated principals in the (continued...)Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
Last modified: May 25, 2011