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             properties without discount as if each property were                     
             sold separately to an individual purchaser.  To use                      
             respondent's terminology, all of the contemporaneous                     
             appraisals valued the properties, both single-family                     
             houses and condominiums, on a retail basis.  They did                    
             not value the subject properties on a wholesale basis;                   
             that is, as if purchased in bulk by a single person.                     
                  Thus, in valuing the single-family homes and the                    
             condominium unit at 4107 Medical Drive, all of the                       
             appraisers used the retail market.  In valuing the other                 
             79 condominiums, on the other hand, respondent's appraisers              
             used the wholesale market and the contemporaneous                        
             appraisals used the retail market.                                       
                  Fourth, in valuing the subject properties, none of the              
             parties relies upon the values that were established in the              
             contracts between EPIC and the sellers of the properties.                
             Petitioners argue that the transactions were arm's-length                
             transactions between unrelated parties, but they take the                
             position that the value of each property is its contract                 
             price, rather than the discounted price that the                         
             partnership actually paid for the property.  On the other                
             hand, respondent argues that the value of each property is               
             a discounted price, as determined in respondent's                        
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