J. Ramsay Farah and Elizabeth Farah - Page 26

          mortgage was on the Berlin house.  Furthermore, it is unlikely a            
          lender would require a change in ownership, but not require that            
          the change be reflected by recordation of a deed of transfer.               
               Maryland law recognizes that ownership of property may be,             
          either formally or informally, separated from title to property.            
          Vlamis v. De Weese, 140 A.2d 665 (Md. 1958).  However, we cannot            
          treat lightly the formal manner in which property is held, lest             
          we subject legal titles to unnecessary uncertainties and                    
          complicate the administration of law.  Estate of Rosenblatt v.              
          Commissioner, T.C. Memo. 1977-12.                                           
               Petitioners had approximately 10 years in which to record              
          the change in ownership of the South Point Road lot, but they did           
          not.  Petitioners contend they had been the owners of the lot               
          since 1992.  However, when selling the property they listed the             
          Family Partnership as its owner.  It was not until petitioners              
          realized ownership of the property through the Family Partnership           
          produced adverse tax consequences that they held themselves out             
          as the owners of the property.  Petitioners were free to organize           
          their affairs as they chose; nevertheless, having done so, they             
          must accept the tax consequences of their choices, whether                  
          contemplated or not.  See Commissioner v. Natl. Alfalfa                     
          Dehydrating & Milling Co., 417 U.S. 134, 149 (1974).                        
               For the foregoing reasons, we hold that petitioners have               
          failed to meet their burden of proving they were the owners of              

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