Kushner v. Commonwealth

KELLEY, Judge.

Michael J. Kushner and Richard D. Kushner (jointly referred to as the Kushners) appeal from an order of the Board of Finance and Revenue which found that the Kushners are required to pay a realty transfer tax as a result of a property transfer from the Kushners to K.B. Investments, a partnership whose sole partners are the Kushners. We affirm.

The facts, as agreed to by both parties in a stipulation of facts dated March 19, 1993, are as follows. The Kushners are brothers and are engaged in the business of owning, developing, leasing and selling real estate. The Kushners are the…