Lowell L. and Marilyn A. Robertson - Page 22




                                       - 22 -                                         
             appraiser, or any other person about the fact that the                   
             Appraisal is wrong on its face.                                          
                  Furthermore, the failure of the Appraisal to set forth              
             the residual value of the equipment upon expiration of the               
             master leases is a serious omission because, as discussed                
             above, the economic return on the investment to the                      
             unitholders depends primarily upon the residual value of                 
             the equipment at that time and not upon expiration of the                
             initial user leases.  As petitioner testified:                           

                  the only way to make a profit in this trans-                        
                  action, is to sell the Equipment at the end of                      
                  the lease term [in 1990]; and that's what I was                     
                  trying to do in becoming an investor in Roscrea                     
                  Trust.                                                              

             Before expiration of the master leases in 1990, the                      
             unitholders could receive fixed rents, equivalent in amount              
             to the payments that the trust was obligated to make under               
             the Trust Note, and a share of contingent rent.  They could              
             not realize the residual value of the equipment until after              
             expiration of the 96-month master leases.  By failing to                 
             provide the residual value of the equipment upon expiration              
             of the master leases, the Appraisal is of limited assis-                 
             tance in computing the economic return on the investment                 
             to the unitholders.  Once again, there is no evidence in                 
             the record that petitioners, the Trustee, or any of the                  






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