- 7 - this purpose was required by HUD. As of the valuation date, GMA held no real estate or other fixed assets and served only as a management company for the housing partnerships to oversee leasing, maintenance, and repair in compliance with HUD requirements. GMA received a management fee from each of the housing partnerships equal to 10 percent of rental income. On the Federal estate tax return, decedent’s interests in the five partnerships were reported at a fair market value of $10,000 each. At the time of decedent’s death, the partnership agreement for each housing project contained a provision granting Fred Jr., or his personal representatives, heirs or assigns, the option to purchase decedent’s interest in said partnership for the sum of $10,000.1 This option provision was contained in each of the original partnership agreements. On December 31, 1990, Fred Jr. exercised these options to purchase decedent’s interests in the four housing partnerships for the payment of the option price of $10,000 for each partnership interest, or $40,000. On 1 Sec. 5.02 of each partnership agreement provides: Notwithstanding any of the foregoing, Fred D. Godley, or his personal representative, heirs or assigns, shall have the option to purchase the Partnership interest of F.O. Godley from either F.O. Godley or his personal representative, heirs or assigns, for the sum of Ten Thousand $10,000. This option may be exercised at any time during the existence of the Partnership. Fred D. Godley shall notify all other Partners in writing of his intention to exercise this option to purchase.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