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the value of real property transferred in order to calculate the
Ohio transfer tax. See Ohio Rev. Code Ann. sec. 319.202 (Ander-
son 1998). The Ohio transfer tax imposed on the University with
respect to its conveyance to Mr. Signom of the Ludlow property
was $506, which means that Mr. Signom, as the grantee or trans-
feree of that property, declared its value to be $253,000. The
Ohio transfer tax imposed on the University with respect to its
conveyance to Mr. Felman of the St. Clair property was $440,
which means that Mr. Felman, as the grantee or transferee of that
property, declared its value to be $220,000. The Ohio transfer
tax imposed on Mr. Signom with respect to his conveyance to the
University of the Irving property was $330, which means that the
University, as the grantee or transferee of that property,
declared its value to be $165,000.
Petitioners anticipated that Mr. Signom would receive quid
pro quo from the University at the closing of the final exchange
transaction on August 1, 1991. Under the final property exchange
agreement, Mr. Signom was entitled to receive quid pro quo from
the University in the final exchange transaction, and pursuant to
that agreement he did receive such quid pro quo in that transac-
tion.
On August 15, 1991, Mr. Deas sent a letter to Mr. Signom
which transmitted to Mr. Signom for his review and approval a
draft of a document entitled “AGREEMENT FOR CANCELLATION OF
LEASE” (August 15 draft acknowledgment). The August 15 draft
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