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appraisers under an income capitalization method. Although a
blockage or market absorption discount has almost always been applied
when a market value was ascertained by a sales comparison method, see
generally Bogdanski, Federal Tax Valuation par. 4.04[4], at 4-11
(1996), we believe that a market absorption discount may apply to
market values ascertained by other methods.
We conclude that the market values of the apartment complexes
are the values ascertained by the appraisers under the income
capitalization method.
3. Assets Traded in the Market
We compare the number of apartment complexes owned by the
decedent to the number of comparable apartment complexes that are
traded in the market over a reasonable period of time. As has been
previously observed, a market absorption discount is applied to
property when the record contains "persuasive evidence that at the
critical time the market was such that it could not absorb sales in
the larger volume at the price level obtaining for small lots".
Richardson v. Commissioner, 151 F.2d 102, 103 (2d Cir. 1945), affg. a
Memorandum Opinion of this Court. We proceed to define the relevant
market for the apartment complexes, and analyze whether the market
could have handled a hypothetical sale of all three complexes.
The record reveals numerous sales of apartment complexes in the
State of Michigan. With respect to sales in Genesee County, however,
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