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University thus transferred to Mr. Signom as part of the August 1
property transfers a total of $295,963 consisting of property
(the Ludlow property valued at $253,000 and $12,000 cash) and
other consideration (relief from the mortgage of $30,963 to which
the Irving property was subject on August 1, 1991, when Mr.
Signom transferred it to the University).
On August 6, 1991, the Irving deed, the July 22 Ludlow deed,
the July 22 St. Clair deed, and the July 22 document were re-
corded in Montgomery County, Ohio (Montgomery County). In order
to record those three deeds, the respective grantors or
transferors of the real properties to which those deeds pertained
and which were conveyed pursuant to the final property exchange
agreement were required to pay (1) a real property transfer tax
imposed by Montgomery County with respect to the respective
transfers of those properties that in this case was equal to $1
for each $1,000 of the respective values of those properties, see
Ohio Rev. Code Ann. sec. 322.02 (Anderson 1998); Montgomery
County, Ohio, Resolution 80-2479 (Dec. 30, 1980); and (2) a fee
imposed by Montgomery County with respect to the respective
transfers of those properties that in this case was equal to $1
for each $1,000 of those respective values, see Ohio Rev. Code
Ann. sec. 319.202(C) and 319.54(F)(3) (Anderson 1998). (We shall
refer collectively to that tax and fee as the Ohio transfer tax.)
At all relevant times, under the law of the State of Ohio, the
grantee or transferee of real property was required to declare
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