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condominium unit at 4107 Medical Drive on a retail basis.
The reason for this in the case of the single-family houses
was suggested in the memorandum of respondent's appraisers,
Messrs. Dalton and Ramos, quoted above, when they stated:
"Multiple sales of single-family houses were not plentiful
at the date of value and at the present date they are very
obscure." In effect, it appears that there was not a
market for multiple sales of single-family houses in 1982
and 1983 when the properties were purchased.
Furthermore, respondent used the retail value of the
single-family houses and the condominium unit at 4107
Medical Drive in computing the percentages and arguing that
the aggregate nonrecourse debt exceeded the value of the
properties by 39.40 percent in the case of EA 83-XII and
19.53 percent in the case of EA 84-III. Respondent does
not argue that the single-family houses and the condominium
unit at 4107 Medical Drive should be valued on a wholesale
basis. Thus, it appears that respondent agrees with
petitioners that these properties should be valued on a
retail basis. Accordingly, we shall review the evidence
in the record to determine the retail value of the single-
family houses and the condominium at 4107 Medical Drive.
The partnerships purchased a total of 26 single-family
houses and the condominium unit at 4107 Medical Drive. As
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