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Leases and have a residual value of not less
than 20 percent of the purchase price.
In that connection, the Tax Opinion further states as
follows:
The Trustee anticipates receiving no positive
cash flow during the initial term of the User
Lease, additional cash flow thereafter depending
upon receipt of any Additional Rent, which cannot
be anticipated but may be significant. Upon
expiration of the [Master] Lease [sic], the
Equipment will be owned free and clear of all
debt and the Appraisal anticipates the Unit-
holders deriving a cash flow thereafter.
However, the Appraisal does not discuss the anticipated
cash-flow from the computer equipment after expiration of
the 96-month master leases.
Finally, the Tax Opinion relies upon the Appraisal
to conclude that the equipment will have "a useful life
extending beyond the terms of the [Master] Leases".
Throughout the Tax Opinion, Austrian, Lance & Stewart note
the importance of the useful life of the equipment in view
of the 96-month terms of the master leases which "is longer
than most leases of such equipment and may indicate that
the anticipated residual value will not be realized."
However, the only statement in the Appraisal that can be
construed as addressing the "useful life" of the subject
equipment is the following: "The IBM 3081 and 4341 Central
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