Epic Associates 84-III, William C. Griffith, Jr. - Page 31




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             additional discounts that must be applied to the retail                  
             value of the property in computing its wholesale value.                  
             In this connection, we note the fact that the builder                    
             fees were treated as having been paid by the seller to                   
             EPIC, as opposed to the partnership, and were reported as                
             income by EPIC, and the fact that the rent advances were                 
             treated as rents and were included in the gross income of                
             each partnership.                                                        
                  In summary, respondent's position is that valuing the               
             subject properties as if sold to separate individuals                    
             yields the retail value of the properties, whereas valuing               
             them as if purchased in a bulk sale yields the wholesale                 
             value of the properties.  Furthermore, according to                      
             respondent, the difference between the retail value and the              
             wholesale value of a particular property is the discount                 
             that EPIC negotiated with each of the sellers, referred to               
             as the rental deficit contribution.  Both of these                       
             positions are set forth in the memorandum written by                     
             Messrs. Dalton and Ramos, the relevant portion of which is               
             quoted above.                                                            
                  Third, the appraisals that were obtained pursuant to                
             EPIC's contracts with the sellers at the time EA 83-XII and              
             EA 84-III purchased the subject properties (referred to                  
             herein as the contemporaneous appraisals) valued all of the              






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