Epic Associates 84-III, William C. Griffith, Jr. - Page 74




                                       - 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 its                      






Page:  Previous  148  149  150  151  152  153  154  155  156  157  158  159  160  161  162  163  164  165  166  167  Next

Last modified: May 25, 2011