- 158 - these cases to show that, as of the initiation of either partnership, such appreciation rates could not be achieved. For example, respondent's appraiser, Mr. Charles D. Brown, testified that in Houston, Texas, property values increased during 1981, 1982, and 1983, even though interest rates were increasing. He testified that if interest rates had dropped, then the real estate market in Houston "would have gone even more ballistic." Moreover, in an internal memorandum, prepared in late 1983 or early 1984, a member of EPIC's management noted that "since 1964, mortgage rates have averaged 2.75% above the inflation rate" and "appreciation rates have also averaged 2.09% above the inflation rate." On the basis of these relationships, the memorandum concludes that EPIC's "partnerships could be expected to generate positive economic benefits". The memorandum also notes that there have been periods, notably 1980, 1981, and 1982, when home price appreciation performed below average, relative to inflation and interest rates. Respondent takes the position that neither EPIC nor any of its limited partnerships, including EA 83-XII and EA 84-III, ever intended to realize a profit. Respondent's position is that EPIC formed EA 83-XII and EA 84-III and other limited partnerships in order to "satisfy itsPage: Previous 148 149 150 151 152 153 154 155 156 157 158 159 160 161 162 163 164 165 166 167 Next
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