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taxpayers were the ultimate consumers of the property.
Accordingly, we looked to the price paid by the taxpayers
as the fair market value of the property. See also Klaven
v. Commissioner, T.C. Memo. 1993-299; Weiss v. Commis-
sioner, T.C. Memo. 1993-228; Rhode v. Commissioner, T.C.
Memo. 1990-656; Weintrob v. Commissioner, T.C. Memo. 1990-
513, opinion modified T.C. Memo. 1991-67, affd. and
remanded without published opinion sub nom. Wagner v.
Commissioner, 31 F.3d 1175 (3d Cir. 1994); Broad v.
Commissioner, T.C. Memo. 1986-340.
At the outset of our consideration of the instant
cases, it is helpful to note several points about the
positions of the parties. First, respondent's appraisers
valued the single-family houses and one condominium unit
on a different basis than they used to value the other 79
condominium units. According to respondent's brief,
respondent's appraisers valued the single-family houses
acquired by each partnership and one of the condominium
units purchased by EA 83-III on a "retail" basis; that
is: "As if the properties were purchased separately by
individuals." Respondent's brief describes the appraisals
of 14 of the single-family houses and the condominium unit
at 4107 Medical Drive as follows:
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