Andantech L.L.C., Wells Fargo Equipment Finance, Inc. (f.k.a. Norwest Equipment Finance, Inc.), Tax Matters Partner, and Wells Fargo & Co., A Partner Other Than the Tax Matters Partner, et al. - Page 103




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          termination dates as having been sold, whether or not they were               
          listed on Schedule I.  Dr. Schallheim also based his conclusion on            
          the fact that Andantech-U.S. did not receive any rent payments from           
          Comdisco.                                                                     
               Thompson Ryan, one of petitioners’ experts, testified that had           
          the projected residual values of the computers been realized, and             
          had Comdisco exercised its early termination option, then the                 
          pretax return for RD Leasing would have been 6.6 percent, as                  
          reflected in the September Projections.  John Deane, one of                   
          respondent’s experts, agreed with Mr. Ryan’s calculation; however,            
          Mr. Deane believed a 6.6-percent return was at, or slightly below,            
          the low end of what an investor would consider acceptable in 1993.            
               The other experts (Ralph Page, Mary O’Connor, and Patrick                
          Callahan for petitioners and Susan Middleton and Peter Daley for              
          respondent) opined as to the reasonableness of the projected                  
          residual values of the computers.  Petitioners’ experts testified             
          that the price paid for the computers was fair and that the                   
          projected residual values were attainable.  Not surprisingly,                 
          respondent’s experts believed otherwise.                                      
               Mr. Daley was the publisher of two industry reports-–the DMC             
          End-User Market Value Report and the DMC Residual Value Report.               
          The information contained in these reports was based on computer              
          (and related equipment) sales between dealers; hence, the amounts             
          reflected in the DMC reports were wholesale (marked up by 10                  
          percent), rather than retail, prices.  On the basis of the                    





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