Myron Barlow and Arlene Barlow - Page 13




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          that leased both Sentinel EPS and EPE recyclers.6                            
               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 expert reports, infra.  Moreover,               
          the recyclers were incapable of recycling expanded polystyrene by            
          themselves and had to be used in connection with extruders and               
          pelletizers.                                                                 
          D.   Expert Reports                                                          
               At trial, petitioners did not offer expert testimony                    
          regarding the value of the recyclers.  Rather, petitioners                   
          stipulated to the expert reports prepared by respondent’s experts            
          Steven Grossman (Grossman) and Richard S. Lindstrom (Lindstrom).             
          Grossman and Lindstrom testified in Provizer v. Commissioner,                
          supra, and a number of other Plastics Recycling cases.                       
               1. Grossman                                                             
               Grossman is a professor in the Plastics Engineering                     



               6  Ulanoff was also the petitioner in Ulanoff v.                        
          Commissioner, T.C. Memo. 1999-170.                                           





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