- 4 - discounted at 14 percent.1 The PPM projections predicted that the total up-front investment by Degree in the energy management systems equipment would be $292,500 in 1981, which means that the net present value of Degree's net receipts was a negative $111,272 ($181,228 less $292,500). Degree claimed that it placed the energy management systems equipment in service during 1981 and that the equipment had a tax basis and fair market value of $8,040,000. Grade's claimed share of the basis in the equipment was $1,339,464 (16.6666 percent times $8,040,000), and petitioner’s claimed share of that basis was $93,800 (7 percent times $1,339,464). The equipment had a true fair market value of no more than $354,000, and Degree's claimed fair market value and tax basis of the equipment exceeded the equipment's true fair market value by approximately 2,271 percent. Petitioner never read the PPM, and she never discussed the PPM with Mr. Mallin. Before participating in Degree, petitioner had no experience in the development, operation, or marketing of energy management systems, she had no knowledge of the components and equipment constituting the energy management systems equipment, and she had no knowledge of whether or not the energy management systems equipment was installed in Milor Corporation. 1 The yield on long-term U.S. Treasury bonds was generally 14 percent in 1981.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011