Donald L. Walford - Page 25

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          Jinnette admitted that he had never seen the EMS purchased by               
          Sav-Fuel and that he was not familiar with the design of the EMS            
          involved in this case.14  Mr. Jinnette acknowledged that some of            
          the equipment could have become obsolete over the years.                    
          Therefore, we assign no weight to Mr. Jinnette’s conclusion                 
          regarding the useful life of the EMS and instead base our                   
          analysis on the assumption in the PPM that the EMS had a useful             
          life of 25 years.  This is the useful life projected at the time            
          the limited partnership interests in Sav-Fuel were offered to               
          investors.                                                                  
                    4.   Anticipated Energy Savings                                   
               The PPM assumes that the savings in electrical energy costs            
          to Gould would be 20 percent of its annual energy bill.                     
          Respondent does not challenge this assumption, and both parties’            
          experts relied on this assumption for purposes of determining               
          projected income.                                                           
                    5.   Inflation Rate of Energy Costs                               
               The PPM assumes that the inflation in energy costs would be            
          20 percent per year.  Petitioner contends that there were energy            
          supply shortages around 1980, and that it was not unreasonable at           

               14We note that the evidence in the record includes a letter            
          from Mr. Jinnette stating that properly maintained industrial               
          equipment of the same type as the EMS has a useful life of 10               
          years to more than 20 years.  This is seemingly inconsistent with           
          petitioner’s assertions and Mr. Jinnette’s statements in his                
          report and at trial that the EMS had a useful life of at least 30           
          years.                                                                      





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