- 19 -
It is readily apparent that the Appraisal is similar
to another appraisal prepared by Mr. Wilkins that was in
issue in Mele v. Commissioner, T.C. Memo. 1988-409. The
appraisal in that case is virtually identical to the
Appraisal at issue in this case, and it is worthwhile to
compare the two. In that case, we described Mr. Wilkins'
appraisal as "a summary of conclusory assertions [that]
provides no substantial basis for measuring the soundness
of projected residual values." Id. We also stated that
"on its face Wilkins' appraisal was not a document worthy
of reliance * * * [because it] is nothing more than a
listing of unsupported conclusions as to the Equipment's
value." Id.
The same is true in the instant case, but there are
also glaring errors in Mr. Wilkins' Appraisal in this case
that are apparent on its face and make reliance on it
unreasonable. First, the second paragraph of the Appraisal
states that there is set forth "the anticipated residual
value for the equipment described in Exhibits A-D upon the
expiration of the initial user lease term and upon the
expiration of 96 months". To the contrary, however, the
Appraisal provides only one set of values and makes no
clear statement about whether the values provided are the
residual values of the equipment upon expiration of the
Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NextLast modified: May 25, 2011