Cynar, P.J.
Petitioners, owners of a federally subsidized, low-income housing project, appeal by right from a judgment of the Michigan Tax Tribunal entered June 3, 1980, by which the tribunal established the true cash value (TCV) of petitioners’ housing project in 1978 and 1979 for purposes of tax assessment.
Petitioners appealed the 1978 and 1979 assessments of the property in question to the tribunal. A hearing was held on November 29, 1979, before a hearing officer, who rendered a proposed opinion finding that the TCV of the property in 1978 was $1,106,000, and in 1979 was $1,110,000. The proposed disposition was objected to, and the tribunal rejected the hearing officer’s proposed opinion and made its own finding that the TCV of the property in 1978 was $1,740,000 and in 1979 was $1,691,000.
On appeal, petitioners contend that the TCV of the property as set forth in the hearing officer’s proposed opinion was correct and that the determination of the tribunal should be set aside.
The property in question is a 120-unit, 15-build-ing apartment complex which was constructed from 1974 to 1976. The property was built with Farmers Home Administration (FmHA) financing of 95 percent of its cost. FmHA issued four loans, secured by mortgages on the property, totalling $1,636,500. Two of the notes were for 50 years, and [630]*630two were for 40 years. Each note carried an interest rate on its face of from 7-3/4 percent to 9 percent. FmHA sets "basic” rents to be charged by the owner. A tenant pays either the basic rent or 25 percent of his or her income, whichever is greater. The owner must enter into an interest-credit agreement to charge only FmHA approved rents. Interest payments on the FmHA loans are waived to the extent that they exceed one percent. Any rent paid above the basic rate (i.e., if 25 percent of the tenant’s income exceeds the basic rent) is paid as additional interest to FmHA. The actual interest paid on this project has never exceeded 1-1/2 percent per annum. The owner of the project also agrees to a variety of other restrictions on his ownership rights, including the obligation to contribute to a repair reserve account. Sale of the property may not take place without FmHA approval.
Where fraud is not alleged, appellate review of determinations of the Tax Tribunal is limited to the question of whether the Tax Tribunal committed an error of law or adopted a wrong principle. Const 1963, art 6, § 28, Northwood Apartments v City of Royal Oak, 98 Mich App 721, 724; 296 NW2d 639 (1980).
Const 1963, art 9, § 3, provides that real property shall not be assessed to exceed 50 percent of the TCV. There are three well-recognized and accepted methods for determining "true cash value”, viz.: market value as determined by comparable selling prices (market method), reproduction cost less depreciation (cost method), and capitalization of income (income method). Consumers Power Co v Big Prairie Twp, 81 Mich App 120, 130; 265 NW2d 182 (1978), Wolverine Tower Associates v Ann Arbor, 96 Mich App 780, 781; 293 [631]*631NW2d 669 (1980). Any of the three methods may be used so long as it is reasonably related to fair market valuation and is accurate. It is the duty of the Tax Tribunal to select the method which, under the facts, is most accurate. Ramblewood Associates v City of Wyoming, 82 Mich App 342, 345-347; 266 NW2d 817 (1978), Wolverine Tower, supra, 782.
Petitioners contend that neither the market approach nor the cost approach produce an evaluation which bears a rational relationship to the TCV of the property and that the subject property can be evaluated properly only by using the income capitalization approach. Petitioners’ appraiser used hypothetical market rents, expenses, and capitalization rate in his analysis. The basic principle behind petitioners’ analysis was their contention that the subject property should be valued as if no favorable mortgage loan and no rent (and other) restrictions were present. They contended that two identical apartment complexes, sitting side-by-side, should receive the same evaluation regardless of special financing arrangements or federal regulation of rents and other property rights.
Respondent’s appraiser used the market approach and contended that a sufficient number of sales of interests in FmHA projects existed to make this a reasonably reliable approach. He testified that the primary value of the projects to investors was as a tax shelter. Respondent’s appraiser studied the unrecorded sales of six FmHA projects. The sales were not made public because FmHA approval is required for such a sale and, whether sought or not, approval had not been granted. FmHA projects were all sold on land contract, with the purchaser assuming the favora[632]*632ble mortgage loan and the unfavorable rental restrictions and other obligations. FmHA projects were typically sold at a percentage over the remaining mortgage balance as shown on the face of the FmHA loans. Respondent’s appraiser testified that the selling price for these projects ranged from 10 to 17 percent above the outstanding mortgage balance. He evaluated the subject property by multiplying the outstanding loan balance by 1.12.
It is true that the petitioners’ income capitalization method previously had been approved as one method of determining true cash value, but that approval was made with the acknowledgment that no reliable information existed on which to base a comparable sales price determination.
The Legislature has defined TCV as "the usual selling price at the place where the property to which the term is applied is at the time of assessment, being the price which could be obtained for the property at a private sale and not at forced or auction sale”. MCL 211.27(1); MSA 7.27(1).
The evidence presented by respondent supports a finding by the tribunal that reliable market data exists to allow a market method valuation of the property. Petitioners do not contend that the market data is inaccurate, but that it is not a proper indication of the value of the property because the value thus obtained is based not on the property itself but on its attendant financing and tax characteristics.
In the recent case of Congresshills Apartments v Twp of Ypsilanti, 102 Mich App 668; 302 NW2d 274 (1981), this Court considered the question of the Tax Tribunal’s assessment of a federally financed and regulated housing project. Congress-hills held that in assessing the property actual income and expenses must be considered as factors [633]*633in determining the TCV of the property and that the tribunal committed an error of law in basing its determination on hypothetical rental rates which the petitioner there legally could not obtain due to the federal regulations limiting rents.
Congresshills does not deal with the market method, but apparently considers only the capitalization of income method. It is instructive, however, in that it required the fact of the existing federal regulations to be considered. Congresshills effectively refutes petitioners’ contention that physically identical properties in comparable locations must receive identical valuations in spite of different financial conditions.
By analogy to Congresshills, it is our opinion that the market method of valuation is appropriate in the instant case and is certainly more reliable than petitioners’ income method.
Congresshills
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Cynar, P.J.
Petitioners, owners of a federally subsidized, low-income housing project, appeal by right from a judgment of the Michigan Tax Tribunal entered June 3, 1980, by which the tribunal established the true cash value (TCV) of petitioners’ housing project in 1978 and 1979 for purposes of tax assessment.
Petitioners appealed the 1978 and 1979 assessments of the property in question to the tribunal. A hearing was held on November 29, 1979, before a hearing officer, who rendered a proposed opinion finding that the TCV of the property in 1978 was $1,106,000, and in 1979 was $1,110,000. The proposed disposition was objected to, and the tribunal rejected the hearing officer’s proposed opinion and made its own finding that the TCV of the property in 1978 was $1,740,000 and in 1979 was $1,691,000.
On appeal, petitioners contend that the TCV of the property as set forth in the hearing officer’s proposed opinion was correct and that the determination of the tribunal should be set aside.
The property in question is a 120-unit, 15-build-ing apartment complex which was constructed from 1974 to 1976. The property was built with Farmers Home Administration (FmHA) financing of 95 percent of its cost. FmHA issued four loans, secured by mortgages on the property, totalling $1,636,500. Two of the notes were for 50 years, and [630]*630two were for 40 years. Each note carried an interest rate on its face of from 7-3/4 percent to 9 percent. FmHA sets "basic” rents to be charged by the owner. A tenant pays either the basic rent or 25 percent of his or her income, whichever is greater. The owner must enter into an interest-credit agreement to charge only FmHA approved rents. Interest payments on the FmHA loans are waived to the extent that they exceed one percent. Any rent paid above the basic rate (i.e., if 25 percent of the tenant’s income exceeds the basic rent) is paid as additional interest to FmHA. The actual interest paid on this project has never exceeded 1-1/2 percent per annum. The owner of the project also agrees to a variety of other restrictions on his ownership rights, including the obligation to contribute to a repair reserve account. Sale of the property may not take place without FmHA approval.
Where fraud is not alleged, appellate review of determinations of the Tax Tribunal is limited to the question of whether the Tax Tribunal committed an error of law or adopted a wrong principle. Const 1963, art 6, § 28, Northwood Apartments v City of Royal Oak, 98 Mich App 721, 724; 296 NW2d 639 (1980).
Const 1963, art 9, § 3, provides that real property shall not be assessed to exceed 50 percent of the TCV. There are three well-recognized and accepted methods for determining "true cash value”, viz.: market value as determined by comparable selling prices (market method), reproduction cost less depreciation (cost method), and capitalization of income (income method). Consumers Power Co v Big Prairie Twp, 81 Mich App 120, 130; 265 NW2d 182 (1978), Wolverine Tower Associates v Ann Arbor, 96 Mich App 780, 781; 293 [631]*631NW2d 669 (1980). Any of the three methods may be used so long as it is reasonably related to fair market valuation and is accurate. It is the duty of the Tax Tribunal to select the method which, under the facts, is most accurate. Ramblewood Associates v City of Wyoming, 82 Mich App 342, 345-347; 266 NW2d 817 (1978), Wolverine Tower, supra, 782.
Petitioners contend that neither the market approach nor the cost approach produce an evaluation which bears a rational relationship to the TCV of the property and that the subject property can be evaluated properly only by using the income capitalization approach. Petitioners’ appraiser used hypothetical market rents, expenses, and capitalization rate in his analysis. The basic principle behind petitioners’ analysis was their contention that the subject property should be valued as if no favorable mortgage loan and no rent (and other) restrictions were present. They contended that two identical apartment complexes, sitting side-by-side, should receive the same evaluation regardless of special financing arrangements or federal regulation of rents and other property rights.
Respondent’s appraiser used the market approach and contended that a sufficient number of sales of interests in FmHA projects existed to make this a reasonably reliable approach. He testified that the primary value of the projects to investors was as a tax shelter. Respondent’s appraiser studied the unrecorded sales of six FmHA projects. The sales were not made public because FmHA approval is required for such a sale and, whether sought or not, approval had not been granted. FmHA projects were all sold on land contract, with the purchaser assuming the favora[632]*632ble mortgage loan and the unfavorable rental restrictions and other obligations. FmHA projects were typically sold at a percentage over the remaining mortgage balance as shown on the face of the FmHA loans. Respondent’s appraiser testified that the selling price for these projects ranged from 10 to 17 percent above the outstanding mortgage balance. He evaluated the subject property by multiplying the outstanding loan balance by 1.12.
It is true that the petitioners’ income capitalization method previously had been approved as one method of determining true cash value, but that approval was made with the acknowledgment that no reliable information existed on which to base a comparable sales price determination.
The Legislature has defined TCV as "the usual selling price at the place where the property to which the term is applied is at the time of assessment, being the price which could be obtained for the property at a private sale and not at forced or auction sale”. MCL 211.27(1); MSA 7.27(1).
The evidence presented by respondent supports a finding by the tribunal that reliable market data exists to allow a market method valuation of the property. Petitioners do not contend that the market data is inaccurate, but that it is not a proper indication of the value of the property because the value thus obtained is based not on the property itself but on its attendant financing and tax characteristics.
In the recent case of Congresshills Apartments v Twp of Ypsilanti, 102 Mich App 668; 302 NW2d 274 (1981), this Court considered the question of the Tax Tribunal’s assessment of a federally financed and regulated housing project. Congress-hills held that in assessing the property actual income and expenses must be considered as factors [633]*633in determining the TCV of the property and that the tribunal committed an error of law in basing its determination on hypothetical rental rates which the petitioner there legally could not obtain due to the federal regulations limiting rents.
Congresshills does not deal with the market method, but apparently considers only the capitalization of income method. It is instructive, however, in that it required the fact of the existing federal regulations to be considered. Congresshills effectively refutes petitioners’ contention that physically identical properties in comparable locations must receive identical valuations in spite of different financial conditions.
By analogy to Congresshills, it is our opinion that the market method of valuation is appropriate in the instant case and is certainly more reliable than petitioners’ income method.
Congresshills relies, in part, on the case of CAF Investment Co v State Tax Comm, 392 Mich 442; 221 NW2d 588 (1974). In dealing with that case, which held that property encumbered with an existing lease that provided a below market income could not be valued on the basis of market income, the Congresshills Court stated:
"The CAF decision stands for the obvious and unremarkable proposition that a buyer will be unwilling to purchase a property based upon current rental rates available in the market where he is unable to enjoy these rates due to an existing lease. It is equally obvious that a potential purchaser will not pay the market rate for an apartment complex where, as here, current market rental rates cannot be obtained due to governmental restrictions.” Id., 677.
We think it is equally obvious that where the chief value of a property in the marketplace is as [634]*634a tax shelter and the price that a buyer is willing to pay at a private sale is determined by that aspect of the property (indeed, it appears that the market for such property is created by the tax-shelter aspect of the property), it is correct to consider the value of the property as a tax shelter in determining the TCV of the property. The Tax Tribunal decision was supported by competent, material, and substantial evidence, and there was no error of law or adoption of wrong principles.
Affirmed.
D. F. Walsh, J., concurred.