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in Robertson I and that we should hold that petitioners are
not liable for the additions to tax under sections 6653(a)
and 6661. Petitioners' arguments require an analysis of
the Appraisal of the subject computer equipment furnished
by Mr. John R. Wilkins, president, Communigraphics, Inc.,
dated December 14, 1982, the Projections that were
furnished to the unitholders, the Tax Opinion rendered by
Austrian, Lance & Stewart, and the Investment Memorandum.
The Appraisal
Mr. Wilkins' appraisal is broken into five sections:
I. Scope of Study; II. Industry Background; III. Valua-
tions; IV. Exhibit A: Equipment Appraised; and V.
Background & Qualifications of John R. Wilkins. The
"Equipment Appraised" section consists of four exhibits,
lettered A through D, which enumerate each item of computer
equipment and state the manufacturer's list price for each.
Set out below is a description of the equipment appraised
as set forth in IV. Exhibits A through D:
Exhibit A: Burroughs Wellcome
Quantity Unit Model Description IBM List Price
1 IBM 3081 D16 Central Proces $3,260,000
1 IBM 3082 16 Processor Cont 220,000
1 IBM 3087 1 Coolant Dist. U 60,000
1 IBM 3278 A02 Console 2,505
3,542,505
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