Pinder v. Dean

ALPERT, Judge.

This “transfer tax” 1 case raises the question of the difference, if any, between the terms “consideration” and “actual consideration.”

The facts are undisputed. George and Jane Dean (the Deans), appellees, purchased two parcels of property. The first was purchased on January 2, 1984, at $130,000. This parcel is known as the Buck Bacchus House. The second parcel, known as the Imperial Hotel, was purchased on April 15, 1984, for $175,000. Both parcels were held as tenants by the entirety.

On May 4, 1984, the Deans created a Maryland corporation which they called the imperial Hotel,…