Lowell L. and Marilyn A. Robertson - Page 25




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             leases.  As mentioned above, the fact that the quarterly                 
             payments under the Trust Note equaled the fixed rent to be               
             paid by Equilease meant that the Trust's income was                      
             effectively limited to two sources:  (1) The Trust's share               
             of contingent rents and (2) the proceeds from the sale of                
             the computer equipment at the end of the 96-month master                 
             leases.                                                                  
                  The Projections show the cumulative after-tax benefit               
             to the Trust on an aggregate basis assuming that the Trust               
             realized additional income from contingent rents through                 
             the end of 1990 in the aggregate amount of $914,175 and                  
             further realized the proceeds from the sale of the computer              
             equipment at the expiration of the master leases in the                  
             amounts set forth.  For example, if the Trust realized sale              
             proceeds amounting to 20, 25, or 30 percent of original                  
             cost of the equipment less a 10-percent sales commission                 
             (i.e., $930,671, $1,163,333, or $1,396,006, respectively),               
             the Projections dated December 16, 1982, show that the                   
             Trust would realize in 1990 a cumulative after-tax benefit               
             of $950,507, $1,072,657, and $1,194,808, respectively.                   
                  Significantly, the forecasted sale proceeds used in                 
             the Projections are not based upon Mr. Wilkins' Appraisal                
             or on the appraisal of any other independent appraiser.                  
             At the first trial, Mr. Scott Binder, who prepared the                   






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