Epic Associates 84-III, William C. Griffith, Jr. - Page 12




                                       - 101 -                                        
             or price concessions that a large buyer would expect                     
             when buying "in bulk".  In fact, as discussed above,                     
             EPIC negotiated with the sellers of the properties various               
             "discounts" in the aggregate amount of approximately 20                  
             percent of the contract price of the properties.                         
             Furthermore, the tax returns filed on behalf of each                     
             partnership compute the partnership's cost basis for                     
             each property under section 1012 as the contract price                   
             of the property less the rental deficit contribution for                 
             that property and claim depreciation on the portion of the               
             cost that was allocated to the improvements.  Petitioners                
             argue that the value of each of the subject properties is                
             equal to the contract price notwithstanding the fact that                
             each partnership paid a price that reflected discounts from              
             the contract price.  Petitioners argue that such discounts               
             "do not reduce the underlying value of any one item                      
             purchased".                                                              
                  Finally, petitioners argue that respondent's evidence               
             relating to the fair market value of the properties is                   
             "rife with errors in assumptions and/or judgement and/or                 
             application of concepts".  Petitioners ask the Court to                  
             conclude that respondent's evidence is biased and not                    
             worthy of consideration.                                                 








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