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The appraisals provided by Century were wholly inadequate. The
VidElect appraisals are identical word for word with the only
exception being the names of the different games. One appraisal
is not even dated. Petitioner testified that he has no
experience in the computer game market and is in fact "not
computer literate." Petitioner made no attempt to market the
video games other than through ALA and, in fact, received no
income from the sale of any games until April 1985, at which time
he received a total of $3.59.
The promotional materials petitioner relied upon prior to
participating in the lease program focus extensively on the tax
benefits of entering into such a venture and contain no
substantive analysis of the economic profitability of the
program. The materials advertise a "write-off" ratio of at least
4.9:1 with a one-time lease payment and essentially no further
action on the part of the investor.
Respondent submitted the report of Mr. Joshua W. Denham of
Rancho Palos Verdes, California, as her expert witness in the
instant case. We evaluate expert opinions in light of the
demonstrated qualification of the expert and all other evidence
of value. Estate of Christ v. Commissioner, 480 F.2d 171, 174
(9th Cir. 1973), affg. 54 T.C. 493 (1970); Parker v.
Commissioner, 86 T.C. 547, 561 (1986). We find Mr. Denham's
report and testimony to be credible. We find that, based upon
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