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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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