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 104




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          information contained in his reports, Mr. Daley opined that the               
          purchase price of the computers was inflated and that the projected           
          residual values of the computers were unattainable.                           
               Ms. Middleton, an expert in the field of residual valuation of           
          mainframe computers at IDC, rebutted the expert opinion of Mr.                
          Page.  She opined that Mr. Page’s estimated economic life for the             
          equipment was too long and explained that IDC projected a 6- to 7-            
          year life for the equipment as of June/July 1993.  On the basis of            
          the residual values forecast by IDC in its IBM June/July 1993                 
          Residual Value Report, the residual value of the equipment on the             
          early termination date was less than $20 million, and on the                  
          termination date it was less than $10 million.  Ms. Middleton                 
          testified that IDC did not take into account (in its residual value           
          forecasting) the value of computers on lease, or the “lease                   
          premium”.                                                                     
               The experts made their evaluation of residual values on the              
          basis of a percentage of list price, as did the three September               
          1993 appraisals.  The following table sets forth the percentages              
          used in the various appraisals as well as the percentages published           
          in DMC’s 1993 publication:                                                    














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