- 3 -
During the year at issue, petitioner was the sole
shareholder of V&M Management, Inc., an S corporation (V&M
Management).2 V&M Management owned and operated a 275-unit
apartment complex known as Mandela Apartments in Roxbury,
Massachusetts.3
On January 8, 1996, V&M Management filed a petition for
reorganization pursuant to chapter 11 of the U.S. Bankruptcy Code
in the U.S. Bankruptcy Court, District of Massachusetts, Boston.
The bankruptcy court appointed an independent trustee, Stephen S.
Gray (the bankruptcy trustee), to administer the reorganization.
In the bankruptcy action, the Commissioner filed proofs of claim
for employment taxes due and owing by V&M Management.
On September 26, 1997, the bankruptcy court confirmed a plan
of reorganization (the plan). The cornerstone of the plan was
the sale of Mandela Apartments and its related property. Because
the plan called for full payment of the employment taxes owed by
V&M Management, the Commissioner had no objection to the plan.
On or about December 18, 1997, the bankruptcy trustee sold
Mandela Apartments and its related property for $2,872,351.
2Petitioner is also listed as owning 100 percent of V&M
Management on its 1998 and 1999 Forms 1120S, U.S. Income Tax
Return for an S Corporation. V&M Management elected to be taxed
as an S corporation on Jan. 1, 1984.
3V&M Management d.b.a. Vasquez Development Co., Inc.,
acquired title to Mandela Apartments from the Secretary of
Housing and Urban Development on Dec. 11, 1981.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011