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practice was a corporation) from the time of its acquisition
throughout the years here in issue and was still being so used at
the date of the trial in this case. From the time of the
acquisition of the Third Street property, throughout the years
here in issue, the expenses connected with the property were paid
by the law partnership or the law practice when it was
incorporated. On August 21, 1972, the remaining portion of lot
14 was conveyed to Murray, Mack, Moosbrugger, & Leonard, P.C.
(the corporation).
Petitioner, Mr. Moosbrugger, and Mr. Murray, along with
their respective spouses, each quitclaimed his interest in lot 14
to the corporation on December 28, 1972. These deeds were
recorded on January 10, 1973.
By quitclaim deed dated December 28, 1972, petitioner and
Mr. Moosbrugger, acting as president and secretary of the
corporation, respectively, executed a mortgage on the Third
Street property in favor of First National Bank, to secure the
corporation's note in the principal amount of $85,000. This
mortgage was satisfied in August 1978.
Even though his interest in lot 14 had been conveyed to the
corporation in December 1972, Mr. Murray conveyed his interest in
this property on September 11, 1974, to petitioner and Mr.
Moosbrugger. The quitclaim deed was recorded 11 months later, on
August 11, 1975.
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