Lowell L. and Marilyn A. Robertson - Page 21




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             To that amount, Mr. Wilkins adds the present value of the                
             payments due under the initial user leases, $4,331,327, to               
             arrive at the aggregate present value of the equipment,                  
             $5,267,715, an amount slightly in excess of the alleged                  
             acquisition cost of the equipment, $5,170,392.  Thus, the                
             premise of the Appraisal is that the fair market value of                
             the equipment sold to the Roscrea Trust is equal to the                  
             present value of the payments due under the initial user                 
             leases, $4,331,327, plus the aggregate present value of the              
             residual values of the equipment upon the expiration of                  
             the initial user leases, $936,388.                                       
                  However, upon expiration of each of the initial user                
             leases, the computer equipment covered by that lease                     
             remained subject to one of the two master leases, and the                
             unitholders could do nothing with that equipment until                   
             expiration of the master leases in 1990, other than to                   
             share with Equilease, the lessee under the master leases,                
             any contingent rents realized.  Thus, in view of the fact                
             that all of the equipment is subject to one of the two                   
             master leases, the Appraisal is wrong in valuing the                     
             equipment at the expiration of the initial user leases.                  
             Significantly, there is no evidence in the record that                   
             petitioners, the Trustee, or any of the other unitholders                
             raised an issue with the seller of the equipment, the                    






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