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An integer of 3.0 represents a gross return of 300 percent of
initial cost. Thus, petitioners' experience indicates that the
total amount of gross rental received on rental units
approximated 300 percent of their initial cost, the percentage
the parties stipulated that the total gross rental anticipated to
be received on each rental unit would equal.
Petitioners provided data only for the 1991 and 1992
calendar years. Since such data for the years at issue was not
readily available without resorting to significant expense,
experience data derived from the 1991 and 1992 calendar years was
utilized. The parties stipulated that petitioners' business
operations and surrounding market conditions remained essentially
unchanged from the years at issue through the years in which such
experience data was derived. Moreover, the parties stipulated
that, due to such continuity, the parties believe that if
petitioners' actual data were available for the calendar years
1987 and 1988, the data, if delineated, would not vary materially
from the experience data delineated for 1991 and 1992.
Consequently, in this particular case, since the parties
stipulated as to the estimate of income expected over the life of
the rental property and this stipulation approximated
petitioners' experience, and since they stipulated that 1991-92
data did not vary materially from the years in question, we hold
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