Prudential Overall Supply - Page 25




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          area of the Carson facility was 562 days.  The median age of the            
          sample of clean room garments from the Bandini Boulevard facility           
          was 422.5 days.                                                             
               Respondent’s expert report is unreliable and not useful                
          because the conclusions reflect an average physical age, rather             
          than the average service life (i.e., useful life).  The                     
          statistical sample used the manufacture date of the items, rather           
          than the placed-in-service date.  The general comments to                   
          respondent’s expert report state:                                           
                    Some items * * * had two labels with different                    
               dates.  One was assumed to be the date at which the                    
               item was manufactured, and the other the date at which                 
               the item was placed in service for the current                         
               contract.  It was sometimes difficult to tell which was                
               which.  This analysis always uses the oldest of the                    
               dates * * *.                                                           
          Here, the oldest date on the label reflected the manufacture date           
          rather than the placed-in-service date.  The sample also included           
          items that were not yet placed in service and items that were               
          withdrawn from service.  In any event, even if the sample that              
          was taken were valid and the conclusions could be relied on, the            
          expert’s conclusions as to the median physical age of the                   
          garments and dust control items do not support the useful lives             
          determined by respondent that would require petitioner to                   
          depreciate the items over either 3 years or 5 years.  Rather, the           
          conclusions would be supportive of and more consistent with                 
          petitioner’s approximations.                                                






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Last modified: May 25, 2011