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(2) no projected equipment rental income to be earned from that
equipment. Respondent’s expert Peter Daley opined that, as of
September 28, 1995, with one de minimis exception, the K-Mart and
Shared equipment would have no estimated residual value by the
critical date, May 1, 2000. The exception concerned photo
equipment with a nominal value of $194.
We emphasize, however, that petitioner did not obtain a pre-
September 28, 1995, outside appraisal of its residual interests.
Instead, Hughes (petitioner’s tax and accounting manager),
sometime before September 28, 1995, prepared a valuation analysis
of those over lease residual interests. Crispin and Hughes both
testified that this valuation analysis was based upon extending
the 10- to 12-year equipment “yield decline curve” that had been
used in the Marshall & Stevens appraisal to value CFX’s first
lease strip deal residual interests in the K-Mart, Shared, and
other existing lease equipment. We note that petitioner did not
offer into evidence any document containing the details of
Hughes’s pre-September 28, 1985, valuation analysis.
In addition, the Marshall & Stevens appraisal was not
received in evidence for purposes of establishing the probative
value of the conclusions therein or as opinion because no expert
testimony was offered. Respondent also points out that this
Court, in other cases, has rejected the valuation methodology of
Marshall & Stevens appraisals in cases involving computer
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