CMA Consolidated, Inc. & Subsidiaries, Inc. - Page 118

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               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              








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