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Investment Memorandum (reproduced as appendix B hereto),
summarized as follows:
Projections Projections Projections
20% 25% 30%
Contingent rent $914,175 $914,175 $914,175
Residual value 930,671 1,163,338 1,396,006
Total 1,844,846 2,077,513 2,310,181
Second, the minimum residual value of the equipment
determined by petitioners' expert, $8,135, is less than
the residual value determined by respondent's expert,
$10,000.
In Robertson I, we also found that there was "a
complete lack of business purpose" for the transaction.
In that connection, we noted that petitioners and the
other unitholders "were partners and principals in a
major accounting firm * * * [and] Petitioner, as well as
other unitholders, had extensive experience with leasing
transactions." Thus, we found that petitioner and the
other unitholders "should have understood that they were
agreeing to a grossly inflated price for their limited
interest in this equipment."
As stated above, the issue to be resolved in this
proceeding is whether the expert testimony presented on
petitioners' behalf during the second trial, together with
petitioners' arguments, convince us that we were mistaken
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