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Properties’ St. Clair property interests. On the instant record,
we reject that contention. We have found on that record (1) that
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, (2) that Mr. Signom was entitled
under the final property exchange agreement to receive quid pro
quo from the University in the final exchange transaction, and
(3) that pursuant to that agreement he did receive such quid pro
quo in that transaction. The quid pro quo that Mr. Signom
received in the final exchange transaction totaled $295,963 and
consisted of the Ludlow property valued in the final property
exchange agreement and for Ohio transfer tax purposes at
$253,000, $12,000 in cash, and 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.
Pursuant to the final property exchange agreement, the
University also received quid pro quo in the final exchange
transaction consisting of the cancellation of MHR Properties’ St.
Clair property interests by Mr. Signom and Ms. Signom as the
general partners of MHR Properties and the transfer to the
University by Mr. Signom in his individual capacity of the Irving
property. The parties agree that MHR Properties’ St. Clair
property interests had a value of $111,500 when those interests
were canceled. The parties do not agree on the fair market value
of the Irving property that Mr. Signom transferred to the Univer-
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