The PA Superior Court recently addressed issues regarding determining the fair market value of property in the context of a “deficiency judgment” proceeding. In Liberty Philadelphia REO, LP v. EFL Partners V, L.P., the Superior Court held that it was proper in that case to fix the fair market value of condominiums based on the developer’s approach. The appellee argued that the appraiser employing that approach used the “bulk sales” approach which it claimed was prohibited by Cheltenham Federal Savings and Loan Associations v. Pocono Sky Enterprises, Inc., 451 A.2d 744 (Pa. Super. Ct. 1982). The Court held the appraisal was proper and that Cheltenham did did not reject the bulk sales approach in all circumstances.