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used in the Projections and the value computed by the
Appraisal. According to Mr. Wilkins' Appraisal, the
"present value" of the computer equipment in 1982 is
$936,388. On the other hand, the Projections assumed
that, if the equipment were sold in 1990 at the end of the
96-month master leases, the proceeds from the sale would
be $930,671, $1,163,338, or $1,396,006. Clearly, if the
proceeds from the sale of the equipment in 1990 are
$930,671, $1,163,338, or $1,396,006, as contemplated in the
Projections, then the equipment could not be worth $936,388
in 1982, as Mr. Wilkins opined in his Appraisal. If we
discount the three sale proceeds used in the Projections at
16 percent, the present values of the sale proceeds in 1982
are $260,959.20, $326,198.79, and $391,438.66. Thus, there
is a significant discrepancy between the value of the
equipment as determined by Mr. Wilkins and the value of the
equipment assumed in the Projections. There is no evidence
in the record that petitioners, the Trustee, or any of the
other unitholders raised an issue about this discrepancy
between the value of the equipment in the Projections and
the Appraisal.
In passing, we note that the Projections contain a
footnote D which states: "At zero residual value the
cumulative benefit amounts to 461905." In the Projections
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