Lowell L. and Marilyn A. Robertson - Page 46




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             the Projections, or the Investment Memorandum that are                   
             described above.  None of the unitholders noted the fact                 
             that the Appraisal fails to set out the residual value of                
             the computer equipment at the expiration of the master                   
             leases and incorrectly values the equipment using the                    
             "residual value" of the equipment upon the expiration of                 
             the initial user leases.  None of the unitholders noted the              
             discrepancy between the value of the computer equipment                  
             determined in the Appraisal and the value of the equipment               
             used in the Projections.  None of the unitholders noted the              
             fact that the Tax Opinion relies upon the Appraisal to                   
             establish the fact that the amount paid by the Trust for                 
             the computer equipment was the fair market value of the                  
             equipment despite the obvious errors in the Appraisal.                   
             Even more significant, none of the unitholders noted the                 
             fact that the Tax Opinion relies upon the Appraisal to                   
             establish facts that are not stated in the Appraisal,                    
             such as the residual value of the computer equipment upon                
             expiration of the master leases and the cash-flow from                   
             the equipment after expiration of the master leases.                     
                  We are simply unable to credit much of the testimony                
             of petitioner and his fellow unitholders regarding their                 
             alleged "independent evaluation" of the subject investment.              
             We do not believe that petitioner and his fellow                         






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