Epic Associates 84-III, William C. Griffith, Jr. - Page 60




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             market, the market in which the partnerships planned to                  
             resell the properties.  The thrust of respondent's position              
             is that the fair market value of the properties, as stated               
             by Messrs. Dalton and Ramos:  "is based on the marketplace               
             in which they were acquired, the wholesale market."                      
             Neither respondent nor respondent's witnesses provide a                  
             reason why this must be the case.                                        
                  During his testimony, Dr. Hewitt touched on the                     
             appropriate market for valuing property and, contrary to                 
             respondent's position, his testimony suggests that the                   
             subject properties should be valued in the retail market.                
             On cross-examination, Dr. Hewitt answered a number of                    
             questions from petitioners' representative about the value               
             of a bag of peanuts as purchased by an individual, on the                
             one hand, or the value of the same bag of peanuts as                     
             purchased by a bulk purchaser, such as an airline, on the                
             other hand.  On redirect, the following exchange took place              
             between Dr. Hewitt and respondent's attorney:                            

                  Q.        Mr. Hewitt, you and Mr. Griffith talked                   
                       about buying peanuts, where he could go buy                    
                       one bag of peanuts and Delta could go buy                      
                       another bag of peanuts.  Let's do this                         
                       example:  You could go to the grocery store                    
                       where a bottle of Coca-cola sells for 50                       
                       cents a bottle, and you can buy a six-pack                     
                       for $2.                                                        








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