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1982 is $3,020,700, or $151,075 more than the aggregate
principal amount of the promissory notes issued by EA 83-
XII to purchase those properties. Similarly, on that
basis, the fair market value of the 40 units composing the
Reflections condominium complex that were purchased by EA
84-III in September 1983 is $3,048,000 or $457,800 more
than the aggregate principal amount of the promissory notes
issued by EA 84-III to purchase those units.
Respondent contends that the condominium units
purchased by each partnership should be valued on a
discounted or wholesale basis. On that basis, respondent
contends, the aggregate fair market value of the 39 units
in Paseos Castellanos purchased by EA 83-XII is $1,800,000,
or $1,069,625 less than the aggregate principal amount of
the promissory notes issued by EA 83-XII. In support
thereof, respondent relies on the appraisal report prepared
by Mr. Harold Mogul.
Mr. Mogul's report states that the highest and best
use of the 39 condominium units is "the use for which the
complex was originally designed and constructed:
Residential Condominium Development." The report begins
by determining "the total retail sales potential" of the
units. Mr. Mogul did this by looking to the prices
received for 23 units in the same condominium complex that
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