- 147 -
which it is "most commonly sold to the public" in the sense
of the "customary purchasers" of the property. Anselmo v.
Commissioner, 757 F.2d at 1212-1214.
It is evident that the subject condominium units were
ready for immediate sale to individual purchasers and that
individual purchasers were among the "customary purchasers"
of condominiums. It is also evident that neither
partnership was the ultimate consumer of the condominiums.
The partnerships purchased the condominiums in bulk
purchases and received substantial discounts from the
sellers, the developers of the properties. The
partnerships purchased the condominiums for the purpose of
reselling them to owner occupants after leasing them for a
period of time. See Goldstein v. Commissioner, supra at
545-546. Therefore, on the basis of the facts of the
instant cases, we find that the retail market was the
appropriate market to use in estimating the fair market
value of the condominiums.
Furthermore, in the instant cases, retail valuation of
the condominium units appears to have been approved by the
marketplace. As discussed in the findings of fact, the
specific loans at issue were initially made by EMI, which
originated the loans and continued to service them; but the
loans were insured by private mortgage insurance companies
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