Epic Associates 84-III, William C. Griffith, Jr. - Page 11




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             mortgage insurance company" and "was purchased by an                     
             unrelated lender shortly after the loan was funded".                     
             According to petitioners, the unrelated mortgage insurers                
             and the lenders who acquired the loans in the secondary                  
             market each "had the incentive to ascertain that the value               
             of the properties was at least equal to the debt" and the                
             fact that they undertook to participate in the transactions              
             is "evidence that the fair market value of the properties                
             was at least equal to the amount of the debt at the time                 
             it was incurred."  Petitioners argue that "the unrelated                 
             lenders and insurers did due diligence" and, in fact "would              
             have exercised special caution with respect to such loans"               
             because of the unusual nature of the loans.  They further                
             argue that the facts show "that there was no attempt by                  
             EPIC to conceal the facts."                                              
                  Petitioners acknowledge that the partnerships                       
             purchased the properties with substantial discounts and                  
             that the partnerships did not pay the contract price for                 
             any of the properties purchased.  As stated in their                     
             posttrial brief:  "common sense suggests that a large                    
             and astute investor [such as EPIC] would demand price                    
             concessions."  Thus, petitioners acknowledge that the                    
             prices paid by each partnership reflected the discounts                  








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