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When the petition was filed in the instant case, petitioner
resided in Roanoke, Virginia.
Petitioner is a licensed general contractor, and a real
estate sales and management broker.
In 1988, petitioner formed Centurion Investments, an S
corporation. Petitioner was the sole shareholder of Centurion
Investments between 1988 and 1996.
Sometime in 1995, petitioner decided to sell for $100,000
Centurion Investments and Roanoke Development, another S
corporation owned by petitioner, to Jane Parker (hereinafter
sometimes referred to as Parker), petitioner’s sales agent.
Centurion Investments and Roanoke Development are hereinafter
sometimes referred to collectively as the Corporations. Parker
began to make payments to petitioner in 1995. See supra note 3.
When petitioner received the entire $100,000 (sometime in 1996),
then he transferred to Parker all his stock in the Corporations
“effective” December 31, 1995.
On January 2, 1996, petitioner sold for $35,000 to Centurion
Investments, or to Parker as 100 percent owner of Centurion
Investments, the following Virginia general partnership
interests: 28a percent interest in Meadow Green Associates;
44.36 percent interest in Williamsburg Manor Associates; 28a
percent interest in Crystal Tower Associates; and 44.36 percent
interest in Spanish Trace Associates. These interests are
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Last modified: May 25, 2011