Lowell L. and Marilyn A. Robertson - Page 35




                                       - 35 -                                         
             Investment Memorandum                                                    
                  Like the Tax Opinion, the Investment Memorandum relies              
             upon the Appraisal's determination of the residual value of              
             the equipment at the termination of the master leases even               
             though the Appraisal does not provide such a value.  For                 
             example, the Investment Memorandum states as follows:                    

                  Based on the prices being paid for new and used                     
                  data processing equipment and the terms of the                      
                  end-user leases thereof, an appraisal by                            
                  Communigraphics, Inc. which has been furnished                      
                  by Seller projects that the Equipment will have                     
                  value at the termination of the [Master] Leases                     
                  more than sufficient to return to an investor                       
                  his capital contribution to the Trust. * * *                        

             Similarly, the Investment Memorandum states as follows:                  

                  Unitholders are urged to review the Appraisal                       
                  attached hereto as Exhibit E, which concludes                       
                  that the Equipment will have a market value of                      
                  not less than 20% of cost at the end of the                         
                  terms of the [Master] Leases.  There is, how-                       
                  ever, no assurance that such value will exist                       
                  or be realized at that time.  (See "Equipment                       
                  Appraisal--Exhibit E".)                                             

             These statements from the Investment Memorandum are                      
             obviously wrong and raise a red flag to any prudent                      
             investor reviewing the Investment Memorandum.                            
                  The Investment Memorandum also relies upon the                      
             Appraisal for the proposition that the fair market value                 
             of the equipment in 1982 is equal to the price paid by the               






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