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phenomenon. The two-tier participants consist
of end-product users (final condominium unit
owners or final single family dwelling
purchasers) and "interim" purchasers. It is the
basic purchase motivation and investment goal
differentials between these two tiers that result
in dramatically different actual price; hence,
value levels. The general misunderstanding of
these differentials also serves as a major
stumbling block to the proper appraisal of, and
underwriting of loans for, such projects. In
view of this, the estimate of market value first
requires a clear recognition of value to whom.
[Id.]
Petitioners take the position that the fair market
value of the condominium units purchased by each
partnership is equal to the sum of the contract prices of
the units, as determined by the contemporaneous appraisals.
As discussed above, the contemporaneous appraisals valued
each condominium unit individually, principally using the
comparable sales approach. Thus, using the terminology
suggested by respondent and Messrs. Dalton and Ramos, as
discussed above, the contemporaneous appraisals valued the
condominium units purchased by EA 83-XII and EA 84-III in
the retail market. Adding together the contract prices of
the individual units to derive the value of the condominium
complex is the "gross sellout" approach referred to in
the portion of Dr. Hewitt's article quoted above. On that
basis, the fair market value of the 39 units in Paseos
Castellanos that were purchased by EA 83-XII in December
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