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that leased both Sentinel EPS and EPE recyclers.5
The offering memorandum represented that Sentinel EPS
recyclers were unique machines. However, they were not. Several
machines capable of densifying low density materials were already
on the market in 1982. Other plastics 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 respondent’s experts, infra.
Moreover, the recyclers were incapable of recycling expanded
polystyrene by themselves and had to be used in connection with
extruders and pelletizers.
D. Respondent’s Experts
At trial, petitioners did not offer expert testimony.
Rather, petitioners stipulated that the Court may adopt its
findings regarding the expert testimony and reports of Steven
Grossman (Grossman) and Richard S. Lindstrom (Lindstrom) as found
in Ulanoff v. Commissioner, T.C. Memo. 1999-170; Gottsegen v.
Commissioner, T.C. Memo. 1997-314; and Fine v. Commissioner, T.C.
Memo. 1995-222. In those cases, we found Grossman and Lindstrom
to be experts in the fields of plastics, engineering, and
5 Ulanoff was also the petitioner in Ulanoff v.
Commissioner, T.C. Memo. 1999-170.
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