- 7 - 1995, WLLC’s assets were transferred to a Florida limited partnership, West Lakeland Land Co., Limited Partnership (WLLC Ltd.), in exchange for a 99-percent limited partnership interest in WLLC Ltd. Fridovich Holdings, Inc. (owned by Debbie Fridovich, petitioner’s sister, and Anthony Fridovich), held a 1-percent general partnership interest in WLLC Ltd. On March 19, 1996, the Internal Revenue Service filed Notices of Federal Tax Lien against WWLC Ltd., naming the partnership as nominee of the estate. On June 13, 1996, WLLC Ltd. brought suit against the United States, see West Lakeland Land Co., Ltd. Partnership v. United States, case No. 96-1157-CIV-T-21 (M.D. Fla.), to quiet title with respect to the partnership property and for release of liens. On October 22, 1996, WLLC Ltd. filed for bankruptcy under chapter 11. See In re West Lakeland Land Co., Ltd. Partnership, case No. 96-14434-8CI (Bankr. M.D. Fla.), appeal docketed, No. 98- 1609-CIV-T25E (M.D. Fla. Aug. 3, 1998). On November 12, 1996, the partnership filed an adversary complaint against the United States in its bankruptcy case, challenging the validity of the Government’s nominee liens. See West Lakeland Land Co., Ltd. Partnership v. United States, 216 Bankr. 892 (Bankr. M.D. Fla. 1998), appeal docketed, No. 98-548-CIV-T23A (M.D. Fla. Mar. 16, 1998). On February 3, 1998, the bankruptcy court entered a judgment and opinion, finding that the nominee liens were invalidPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011