Blacknall v. District of Columbia Rental Housing Commission

It is troubling, at least to me, that coverage under the rent control laws can be avoided, and the tenants’ rent can be almost tripled,1 by conveying the premises from mother to daughter for the princely sum of $10.00.2 In situations which appear to me to be analogous in principle, transfers between family members are treated as suspect and are subject to special scrutiny by the courts, especially where no consideration has been paid. See C.I.R. v. Tower, 327 U.S. 280, 291, 66 S.Ct. 532, 537, 90 L.Ed. 670 (1946); Sence v. United States, 184 Ct.Cl. 67, 394 F.2d 842, 852 (1968) (avoidance of…