From time to time, yes. Often times people hear the term "short sale" and instinctively think of a seller that is in default and needing to sell their home promptly to avert further financial problems. This is sometimes the case and can be an opportunity for a buyer to cash in on another's misfortune. On the other hand, a lender may consider a short sale even if the seller is current with their mortgage, but property values have declined. In these cases the reduced price may in fact be in line with true market values rather than below.
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