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sum of any money received plus the fair market of the property
(other than money) received."
Since the amount of money received by Pecaris did not exceed
$4.1 million, we must address whether the $700,000 credit is
properly includable in the amount realized by Pecaris. In this
connection, Mr. Berardinelli, the president of Continental, the
escrow agent, testified that it's common practice in escrowed
real estate transactions for the escrow agent to make offsetting
or netting entries in the escrow account to reflect offsetting
obligations and to pay the net amount due to the party entitled
thereto. The additional consideration given by Coastal was the
$700,000 credit to petitioner's capital account in Coastal. The
way in which the capital account credit served as a substitute
for a $700,000 cash payment from Coastal to Pecaris can be seen
by analyzing the network of obligations arising from the sale of
the Mall. Coastal was obligated to pay Pecaris $700,000 over and
above the proceeds of the new mortgage financing. Through a
combination of petitioner's actions and the profit-sharing
provisions of the Pecaris partnership agreement, Pecaris was
obligated to pay to petitioner or at his direction a total of
$795,783, consisting of $695,783, the 25-percent distributive
share of the net proceeds of the sale, plus the $100,000
brokerage commission. Petitioner was paid $95,783 from escrow,
leaving an unpaid balance of $700,000 that was satisfied by the
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