Epic Associates 84-III, William C. Griffith, Jr. - Page 28




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                  Respondent's appraisals, which were performed 11                    
                  to 13 years after EA83-XII and EA84-III acquired                    
                  the properties, reflect retail values of the                        
                  houses at 2109, 2111, 2115, and 2117 Avignon                        
                  Drive in Carrollton, the seven houses in Odessa                     
                  [viz, 1612 Hemphill Avenue, 1921 West 17th                          
                  Street, 1728 Coronado Avenue, 1700 Linda Avenue,                    
                  1716 Coronado Avenue, 1916 Hollywood Drive, and                     
                  1720 Coronado Avenue], the two houses at 5411 and                   
                  5419 Heronwood Drive in Humble, the condominium                     
                  at 4107 Medical Drive in San Antonio, the house                     
                  at 4850 W. Ferret Drive in Tucson as if the                         
                  properties were purchased separately by                             
                  individuals.  [Emphasis supplied.]                                  

             Similarly, respondent's brief describes the appraisals of                
             the other 12 single-family houses as follows:                            

                  Respondent's appraisals, which were performed 11                    
                  to 13 years after EA83-XII and EA84-III acquired                    
                  the properties, reflect retail values for the                       
                  residences at 2113 Avignon in Carrollton, 13739                     
                  Earlywood Drive and 6402 Ridgecreek Drive in San                    
                  Antonio, and 3518 Tower Hill Lane, 12347                            
                  Northcliffe Manor Drive, 13066 Clarewood Drive,                     
                  6351 S. Briar Bayou, 12231 Carola Forest Drive,                     
                  and 12103, 12107, 12111, and 12115 Kingslake                        
                  Forest Drive in Houston as if purchased                             
                  separately by individuals.  [Emphasis supplied.]                    

                  On the other hand, respondent's appraisers valued the               
             condominium units acquired by each partnership (other than               
             the condominium unit at 4107 Medical Drive) on a                         
             "wholesale" basis; that is, as if the purchase consisted                 
             "of multiple properties purchased in bulk sales from the                 
             same builder."  Respondent's brief states as follows:                    








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