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and Mr. Giorgi signed the purchase agreement on behalf of
Coastal. Petitioner acted on behalf of both Pecaris and Coastal
in consummating the transaction.
On the basis of Canada Life's valuation, the Mall had some
value in excess of the stated purchase price of $4.8 million.
However, there is no other evidence in the record that bears on
the fair market value of the Mall or of petitioner's 25-percent
partnership interest in Pecaris, either in gross or with respect
to his partnership interest in Pecaris attributable to its
ownership of the Mall. Petitioner's proportionate interest in
the Mall was subject to liabilities and closing costs of
$504,314, giving him a net equity interest in the Mall of
$695,686, if its value should be deemed to be the agreed purchase
price of $4.8 million.4
4The liabilities and closing costs to which the Mall and a
25-percent interest therein were subject were as follows:
Stated purchase price of Mall . . . . . . . . . . . . $4,800,000
Capco Enterprises mortgage $1,765,344
Security deposits 35,445
Real property taxes 23,380
Prepaid rents 19,532
Adjustment for real estate commission 100,000
Closing costs 73,553 2,017,254
Pecaris equity in Mall, valued
at $4.8 million . . . . . . . . . . . . . . . . . 2,782,746
25 percent of stated purchase price of Mall . . . . 1,200,000
25-percent share of costs and
liabilities . . . . . . . . . . . . . . . . . . . 504,314
Petitioner's 25-percent equity in
Mall, if it should be valued at
$4.8 million stated purchase price . . . . . . . . 695,686
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Last modified: May 25, 2011