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the Putnam County property. In March 1983, the Thompson
partnership defaulted on its mortgage and deeded most of the
Putnam County property back to decedent and petitioner because
the partnership could not get the residential zoning it needed to
develop the property and because the property did not have as
much timber on it as the realtor (Tom Schifanella) had
represented to the buyers. Later that year, petitioner and
decedent resold about 400 acres to Gerald Thompson (Thompson) for
$300-$400 per acre. Thompson sold that land to other developers
at a date not specified in the record for about twice as much as
he paid. Decedent and petitioner sold the remaining Putnam
County property to Marc K. Massar for $450 per acre at a date not
specified in the record.
4. The 1983 Transfer From Decedent to Petitioner
On December 7, 1983, decedent transferred to petitioner an
undivided one-half interest in the Clay County property. The
deed stated that the transfer was made for consideration of $10.
The deed had affixed to it a $225 documentary stamp tax dated
February 21, 1984. Decedent's use of a $225 documentary stamp
tax was a representation that the interest she transferred to
petitioner was worth $50,000. Petitioner gave decedent no money
for the Clay County property.
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