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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,
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