Dennis W. Stark - Page 3




                                        - 3 -                                         

          Middlebelt Road, Garden City, Michigan (Automotive Property).               
               In 1984, William bought his brother-in-law's one-half                  
          interest in Lakeview's predecessor partnership, thereby acquiring           
          a 100-percent ownership interest.  That same year, William                  
          incorporated Lakeview, and he and petitioner became 50-percent              
          shareholders.2   William retained direct ownership of the                   
          Automotive Property, however.                                               
               William also owned the lot adjacent to the Automotive                  
          Property, at 6435 Middlebelt Road (Fence Property), on which he             
          operated the Stark Fence Company.  The rear and side doors of the           
          Automotive Property building were not accessible except through             
          the Fence Property.  On September 29, 1989, for the consideration           
          of $1, William transferred the Fence Property to Lakeview Realty            
          Company, a general partnership formed on the same date and in               
          which William and petitioner each owned a 50-percent capital                
          interest.  There is no evidence that petitioner made any capital            
          contribution to the Lakeview Realty Company partnership in                  
          exchange for his 50-percent capital interest.  The Fence Property           
          was appraised at $150,000 on October 30, 1989.  Also on September           
          29, 1989, William conveyed his interest in the Automotive                   
          Property by a quitclaim deed to Lakeview for the consideration of           
          $1.                                                                         
               Petitioner and William began to have disagreements that made           


               2 Lakeview elected S corporation status on Dec. 23, 1988.              




Page:  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