Epic Associates 84-III, William C. Griffith, Jr. - Page 18




                                       - 107 -                                        
             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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