- 4 - became shareholders of Good Shepherd on January 6, 1986. Petitioners Valdis and Vaida Vipulis are individuals who made a joint return of income for 1985 and resided in Cold Springs, New York, at the time their petition was filed. Petitioner Valdis Vipulis became a shareholder of Good Shepherd on December 8, 1985. Good Shepherd is an Indiana corporation, incorporated on December 30, 1985. All of petitioners, and Good Shepherd, are calendar year taxpayers. (We will use the term "shareholders" to refer to those petitioners who were shareholders of Good Shepherd.) The Property, Ona Pranckeviciute, and Lithuanian Good Shepherd Home Central to our discussion is a parcel of real property located in Cedar Lake, Indiana (the property). Sometime during the summer of 1982, Ona Pranckeviciute (Ona) purchased the property from the Salesian Society, Inc. (Salesian). In the contract of sale between Ona and Salesian, the property is described as an approximately 86-acre tract containing the following improvements: scholastic building, cafeteria, dormitories, gymnasium, chapel, and water plant. Ona agreed to pay $1 million for the property. She paid $100,000 immediately, and she agreed to pay the remaining $900,000 in installments, without interest, her installment obligation (the Salesian obligation) being secured by a mortgage against the property (thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011