- 14 - The experts who testified at the first trial on behalf of each of the parties valued the contingent rents and residual value of the equipment at the end of the master leases as follows: Lyons Lyons Minimum Maximum Blumenthal Contingent rent $659,363 $925,877 $417,179 Residual value 8,135 470,074 10,000 Total 667,498 1,395,951 427,179 We adopted the view of respondent's expert, Mr. S. Paul Blumenthal, that $427,179 was the maximum amount that would be recouped by the unitholders. Accordingly, we found that they could not recoup their cash payment of $954,000 and, thus, could not realize an economic profit. This analysis is similar to that applied in other court cases. See Rice's Toyota World, Inc. v. Commissioner, 752 F.2d 89 (4th Cir. 1985); Estate of Strober v. Commissioner, T.C. Memo. 1992-350; Mele v. Commissioner, T.C. Memo. 1988-409; Dobbs v. Commissioner, T.C. Memo. 1987-361. There are several aspects of the testimony of petitioners' expert, Mr. Esmond C. Lyons, Jr., that should be noted. First, the aggregate minimum economic benefit, $667,498, and the aggregate maximum economic benefit, $1,395,951, are both substantially less than the economic benefit set forth in the Projections that accompanied thePage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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