- 7 - 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 . . . . . . . . 695,686Page: 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