We investigate the ability of three-integral, axisymmetric, orbit-based modeling algorithms to recover the parameters defining the gravitational potential (M/L ratio and black hole mass Mh) in spheroidal stellar systems using stellar kinematical data. We show that the potential estimation problem is generically under-determined when applied to long-slit kinematical data of the kind used in most black hole mass determinations to date. A range of parameters (M/L, Mh) can provide equally good fits

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... to the data, making it impossible to assign best-fit values. We illustrate the indeterminacy using a variety of data sets derived from realistic models as well as published observations of the galaxy M32. In the case of M32, our reanalysis demonstrates that data published prior to 2000 are equally consistent with Mh in the range 1.5x10^6-5x10^6 solar masses, with no preferred value in that range. While the HST/STIS data for this galaxy may overcome the degeneracy in Mh, HST data for most galaxies do not resolve the black hole's sphere of influence and in these galaxies the degree of degeneracy allowed by the data may be substantial. We investigate the effect on the degeneracy of enforcing smoothness (regularization) constraints. However we find no indication that the true potential can be recovered simply by enforcing smoothness. For a given smoothing level, all solutions in the minimum-chisquare valley exhibit similar levels of noise. These experiments affirm that the indeterminacy is real and not an artifact associated with non-smooth solutions. (Abridged)