Bjurback v. Commissioner of Revenue Services

The single issue in these cases is whether a conveyance of real estate to a corporation wholly owned by the grantor is subject to a real estate conveyance tax based on the amount stated in the deed or on the value of the interest being conveyed. Both cases involve a transfer of real estate to a corporation wholly owned by the grantor, followed immediately thereafter by a conveyance from the corporation to a nonrelated third party for the full value of the property.

In the first case, the plaintiff, Stanley Bjurback, the sole shareholder of Scandesign Homes, Inc., a Connecticut construction…