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in the schedule above, none of the loans issued by the
partnership materially exceeds the value of the related
property, as determined by respondent's appraisers.
Similarly, in the case of the properties acquired by EA
84-III, other than the Reflections condominium units, 7 of
the 15 loans issued by the partnership are 110 percent or
less of the value of the related property, as determined
by respondent's appraisers. Nevertheless, respondent
determined that all of the loans issued by both partner-
ships are not bona fide because the aggregate principal
amount of the loans issued by each partnership exceeds the
aggregate value of the properties by 39.4 percent in the
case of EA 83-XII and 19.53 percent in the case of EA 84-
III. Petitioners do not take issue with this aspect of
respondent's approach and the parties do not address the
issue whether the value comparison should be made in the
aggregate or loan by loan.
In these cases, we must determine whether the fair
market value of the properties acquired by each partner-
ship is more or less than the principal amount of the debt
that was incurred by the partnership in purchasing the
properties. For purposes of making this comparison, we
must determine the fair market value of the properties as
of the time they were acquired by each partnership. See,
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