- 143 - value of the subject properties must be based upon the bulk purchase price, the wholesale price, rather than the value of each single unit because: The potential market risk [to each partnership] is actually related to multiple units and not a single unit as would be unrealistically reflected by the EPIC/CAG approach of solely obtaining individual unit appraisals. In his testimony, Dr. Hewitt elaborated on that concept as follows: What I was illustrating in the report is that if you look at the way Epic appraised the properties, they specifically, by the directive of their captive appraisal group, dictated that the appraisals be done on an individual basis, despite the reality that their purchases were done in bulk. And what I am saying is is [sic] that discount was represented because of the fact that they, in fact, had a risk exposure relating to a bulk purchase, so they paid a fair price for buying 50, 60, 150 or 200. They may have–and I am trying to illustrate, which is really the difficult concept in this whole Epic matter-–is there is a significant difference between the one-house-at-a-time appraisal versus the risk, the portfolio risk of having 50, having 100, having 250. On the basis of that statement, respondent asks the Court to make the following finding of fact:Page: Previous 133 134 135 136 137 138 139 140 141 142 143 144 145 146 147 148 149 150 151 152 Next
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