William N. Kellahan, Jr. and Alice H. Kellahan - Page 7




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          corporation owned by Mr. Dibble.  For purposes of the foregoing             
          transfer, Mr. Askins and Mr. Dibble treated the property as                 
          having an exchange value of $160.  Finally, the Canal was deeded            
          from Blue, Inc., to petitioners on December 10, 1990, for                   
          consideration of $10 and the exchange of other property.5  Four             
          days later, on December 14, 1990, petitioners contributed the               
          Canal to the South Carolina Public Service Authority (SCPSA).               
          Petitioners contributed the Canal because the Clarendon County              
          Tax Assessor had advised petitioner that the owners of the 28               
          lots surrounding the Canal were very upset that the Canal had               
          been sold and had suggested that petitioner either attempt to               
          work out some kind of agreement with the owners or give the                 
          property to the SCPSA.  Petitioners decided to contribute the               
          property to the SCPSA so they would not have to deal with the               
          disgruntled owners.                                                         
               At the time they contributed it, petitioners had not visited           
          the property and knew very little about it.  In fact, petitioners           
          did not visit the property until approximately 1 month prior to             
          the trial in this case.  However, petitioner received a letter              
          dated December 14, 1990 (the date of the contribution), from                
          Harby Moses, Jr., a licensed contractor doing business as Coastal           



               5 The record does not indicate what property was exchanged,            
          or its value.                                                               




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