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          evidence in the record reflects that this was the partnership’s             
          only asset and source of income.  Thus, the proper net present              
          value analysis in this case should be for a term of 25 years.               
          Although Mr. Horvey’s calculations are helpful through the year             
          2005, his ultimate conclusion based on a 50-year cashflow                   
          analysis is misplaced.                                                      
               Respondent’s argument that the appropriate discount rate to            
          apply is 18.96 percent is based on the report and testimony of              
          Ken D. Howell (Mr. Howell), a petroleum engineer.  Mr. Howell is            
          currently responsible for conducting independent examinations of            
          tax returns filed by large organizations.  His duties require               
          knowledge of engineering valuation principles, tax law, and                 
          industry practice, and for the last 12 years he has prepared                
          written technical and valuation reports to taxpayers.                       
               Mr. Howell used the buildup method18 to arrive at a discount           
          rate he felt was appropriate.  Mr. Howell stated that the average           
          rate of return on a 20-year U.S. Government bond in 1980 was                
          11.36 percent (which would be the risk-free rate of return for              
          1980).  Mr. Howell felt that it was appropriate to add an equity            
          risk premium to this figure to arrive at the discount rate.                 
          Using historical data published in Stocks, Bonds, Bills, and                
               18According to Mr. Howell, the buildup method is an additive           
          model in which the return on an asset is estimated as the sum of            
          a risk-free rate and appropriate risk premiums, such as equity              
          risk and firm size risk.                                                    
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