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petitioners' experience indicates that the vast majority of
rental units ceased to be in their inventory due to customers'
retaining the rental units for the full term of the rental
contract (be it the initial rental contract or the subsequent
rental contract). If a customer retained the rental unit for the
full term of the rental contract, title to the rental unit vested
in the customer at no additional cost, provided the customer had
paid all periodic rental payments.
In the Carland case, we determined the salvage value of the
taxpayer's property based on a percentage of salvage proceeds to
original acquisition costs. Id. at 547.
In this case, each Entity's 1991 and 1992 experience data
indicates that its percentage of sales proceeds derived from
sales of rental units to third parties by category, such
percentage being equal to the ratio such total sales proceeds
bore to the total initial purchase price of all rental units in
that category, was as follows:
Category Percentage
Guaranteed ABC
Appliances 2.0 2.7
Televisions Less than 1 5.5
Furniture 2.3 2.4
Stereos Less than 1 Less than 1
Video Cassette Recorders Less than 1 Less than 1
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