- 84 -
Regarding the K-Mart photo processing equipment, Svoboda’s
level of experience and expertise in valuing equipment with a 10-
year or less useful life is inferior to that of Daley.
Accordingly, we give less weight to Svoboda’s conclusions
regarding (1) the fair market values of the K-Mart photo
processing equipment and the Shared computer equipment, (2) the
estimated residual value of the K-Mart equipment, and (3) the
fair market value of petitioner’s over lease residual interests
in the K-Mart and Shared equipment.
Although Daley’s opinion was also lacking in detail, we have
more confidence in Daley’s valuation and find his approach and
assumptions to be more reasonable. His fair market and residual
value opinions were based on objective market data.
Consequently, we rely on Daley’s conclusions with respect to
(1) the fair market values of the K-Mart and Shared equipment,
(2) the residual values of the K-Mart and Shared equipment, and
(3) petitioner’s projected equipment rental income from its over
lease residual interests.
We find as an ultimate fact that as of September 28, 1995,
the K-Mart photo processing and Shared computer equipment had no
residual value. We further find as an ultimate fact that as of
September 28, 1995, petitioner’s prospect for realizing equipment
rental income and/or other income from the over lease residual
Page: Previous 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 NextLast modified: May 25, 2011