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Processors and the IBM and Control Date [sic] Corporation
disk are the latest model in their price and capacity
ranges, and should have an economic life of not less than
twelve years." This statement concerning the "economic
life" of the equipment is not formulated in terms of
Mr. Wilkins' considered opinion but appears to be an off-
hand conclusory comment without anything to support it.
In summary, therefore, the Tax Opinion relies upon the
Appraisal without question, even though there are glaring
errors that are evident on the face of the Appraisal and a
discrepancy between the value of the equipment in the
Appraisal and in the Projections. The Tax Opinion also
relies upon the Appraisal to establish facts, such as the
residual value of the equipment upon expiration of the 96-
month master leases, and the cash-flow from the equipment
upon the expiration of the master leases, that are not
stated in the Appraisal. Finally, the Tax Opinion relies
upon the Appraisal to establish the "useful life" of the
equipment, even though the statement in the Appraisal
regarding the "economic life" of the equipment does not
define the term "economic life" and appears to be an off-
hand comment, rather than the considered opinion of the
appraiser.
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