Epic Associates 84-III, William C. Griffith, Jr. - Page 62




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             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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