Market Value is the Price of Holdover Tenancy

A tenant has an implied duty to vacate at the end of the lease term and, when a contract does not specify the rate to apply, a holdover tenant must pay damages at the market lease rate. In J. Leonard Spodek, the PSBCA averaged the calculations of each party's expert appraisal after finding that one expert had understated and the other overstated the market rate.