Donald L. Walford - Page 8

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          basis of these assumptions, the economic projections show a net             
          cashflow of $2,453,398.  The income projections in the PPM are              
          not discounted to present value.                                            
               According to the PPM, depreciation on the EMS was expected             
          to total $1,478,571 for 1980.  This was based on Sav-Fuel’s use             
          of the Class Life Asset Depreciation Range method to depreciate             
          the EMS on a double declining basis over 7 years.  The PPM also             
          states that the partnership anticipated approximately $2,070,000            
          in 1980 for investment tax credits and energy credits.                      
               The PPM states that to the extent that fuel prices do not              
          continue to increase through 2005 at the rate projected, Sav-Fuel           
          will be unable to achieve the gross income and return to its                
          limited partners as set forth in its economic projections.  The             
          PPM also recognizes that the development of new processes or                
          technology could result in the possible obsolescence of the EMS.            
               Over 30 of the past 35 years, petitioner has worked as a               
          stockbroker and investment banker.  At the time of his investment           
          in Sav-Fuel, petitioner had no knowledge of the partnership other           
          than that obtained from reviewing the PPM.  Petitioner has no               
          personal knowledge of the EMS.                                              
               Petitioner and his former wife’s jointly filed 1981 Federal            
          income tax return was mailed to respondent on March 11, 1983.  On           
          the return, petitioner claimed a deduction of $18,956, his                  
          distributive share of the partnership losses from Sav-Fuel.  The            






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