-5-
with his children would make it difficult to attach. Upon
formation of the Family Partnership, Dr. and Ms. Farah each held
a 35-percent interest. Two of their four children, Frederick
Farah (then age 17) and Veronica Farah (then age 11), each owned
15-percent interests.4 The partnership agreement was signed by
Dr. and Ms. Farah. It was not signed by either of their
children, nor did either child make a capital contribution to the
Family Partnership. The Family Partnership did not register as a
business entity in the State of Maryland or obtain an employee
identification number.
On the day of its formation, the Family Partnership
completed the purchase of the South Point Road lot. At the time
of purchase, the only structure on the lot was a tool shed.
There was no separate electricity line, well, sewer line, or
septic system. At the closing, petitioners paid $51,880 in cash.
The balance of the purchase price was financed through a
promissory note and a purchase money mortgage to the seller made
by the Family Partnership.
Petitioners made improvements to the South Point Road lot.
They constructed a bulkhead and concrete path that extended along
the shoreline from the Berlin Residence property into the South
Point Road lot to protect the property from the water. They also
constructed a fence that went around both properties. The lots
4Petitioners also had two older children, Patrick Farah and
another whose name was not disclosed in the record.
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Last modified: March 27, 2008