Dear Sara,
The banks normally "list" new properties at the highest possible value normally based on an appraisal prepared by an appraiser who does not actually do many appraisals in that area, which means athey are going to be flawed. The only problem with writing a low ball offer takes the risks of it being rejected or pushing a higher priced offer into a better position.
Depending where you got your comps I would suggest this;
Make sure the Realtor who is representing you has an in depth knowledge of the market area and the selling of REO's (foreclosures). Based on the comps created by that area specialist, concur that the house is only worth $197K I would start near that figure.
One thing to consider is that the property has probably set vacant for up to a year and there may be some issues so make sure your Realtor includes language in your contract that allows for building and environmental inspections .
Frank J Helderle
RE/MAX Best Choice
REO Short Sale Specialist
FSREOC, SFR, FSSSC, CDPE - Fri Oct 1, 2010