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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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