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Print 1985). The 11.5-month period of zero rent provided in the
lease agreement fits squarely within the definition of a rent
holiday in the committee report, and it is not necessary for the
lease agreement to label it as such.
Respondent also contends that the 11.5-month period of zero
rent cannot qualify as a reasonable rent holiday described in
section 467(b)(5)(C) because at the time Partnership and BCE
entered into the lease agreement in June 1988 the inclusion of
rent holidays in commercial leases was a reasonable and accept-
able practice in the Denver office market only for commercial
leases under which the lessees occupied the leased space, and the
lease agreement was not such a lease. Rather, it was a master
lease under which BCE, albeit the lessee, was not to occupy
Republic Plaza except for a small amount of space; instead, BCE
was to sublease space in that office building to other persons
who were to occupy it.
To counter respondent's arguments and to support its posi-
tion that the 11.5-month period of zero rent qualifies as a
reasonable rent holiday described in section 467(b)(5)(C),
petitioner relies, inter alia, on the opinions of two expert
witnesses, Mr. Atkins and Mr. Whitcomb, who are qualified as
experts in real estate appraisal and who prepared the Marshall
and Stevens appraisal report.
We evaluate the opinions of experts in light of the quali-
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