- 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 companiesPage: Previous 137 138 139 140 141 142 143 144 145 146 147 148 149 150 151 152 153 154 155 156 Next
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