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market value of each of the eight properties as of
September 1983.
Condominiums
Unlike the single-family residences, it appears that
there was both a retail market and a wholesale market for
condominiums at the time the partnerships purchased the
condominium units at issue in these cases. Respondent's
principal expert witness, Dr. Richard Hewitt III, wrote an
article in 1980, in which he described a "double-tiered
market" for condominiums. Hewitt, "Condominium/Developed
Lot Discounting Concepts...Again", 46 Real Estate Appraiser
and Analyst (Jan.--Feb. 1980). Dr. Hewitt noted that in
valuing condominiums some persons advocated using the gross
sellout amount, the sum of the retail sale prices of the
condominiums, as the market value, while others advocated
using a discounted or wholesale value. See id. According
to Dr. Hewitt: "both are correct under certain
circumstances". Id. Dr. Hewitt wrote the following:
Numerous questions continue to arise relative to
what exactly is market value for condominium/
developed lots. Certain advocates promote the
idea that gross sellout (summation of retail
sales prices) constitutes market value, whereas
others have advocated the use of discounted
value (or wholesale value). Actually, both are
correct under certain circumstances due to what
can best be described as a double-tiered market
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