Marshall I. Gordon - Page 2

                                        - 2 -                                         

          in Blackbob, a Kansas property, and (2) whether he is liable for            
          a section 6661(a) addition to tax.  The facts have been                     
          stipulated.  Unless otherwise indicated, all section references             
          are to the Internal Revenue Code in effect for the year in issue,           
          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.                                                              
               Marshall I. Gordon, petitioner, resided in Overland Park,              
          Kansas, when the petition in this case was filed.  Petitioner and           
          his sister, Suzanne Aron (Suzanne), were in dispute over the                
          estate of their late father, Milton Gordon, and assets owned by             
          Gordon Realty Company, Inc. (Gordon Realty).  They agreed to                
          submit all of their differences to binding arbitration.                     
               Gordon Realty owned an undivided 5/6 interest (83.333%) in             
          Blackbob, a plot of land located at 135th and Blackbob, Johnson             
          County, Kansas (Blackbob).  Of the 900 shares of common stock               
          outstanding in Gordon Realty, petitioner owned 486 shares,                  
          Suzanne owned 269 shares, and their respective children owned the           
          remaining shares.  Pursuant to a plan of liquidation under which            
          it was required to distribute all of its property and assets,               
          Gordon Realty conveyed to petitioner, Suzanne, and their                    
          respective children undivided proportionate ownership interests             
          in real estate (including Blackbob) of 45.001 percent, 24.907               
          percent, and 13.425 percent, respectively.  The remaining 1/6               
          interest (16.667%) in Blackbob was owned by Milton Gordon,                  





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  Next

Last modified: May 25, 2011