Dupont Park Apartments, Inc. v. District of Columbia, District of Columbia v. Dupont Park Apartments, Inc.

On January 4, 1963, in the course of liquidation, Dupont Park Apartments, Inc., conveyed to trustees for its stockholders real property of the fair market value of $1,900,000. Any deed recorded in the District of Columbia is subject to a “recordation” tax of % of 1 percent of “the consideration for such deed.” 76 STAT. 12 (1962), D.C.Code, Supp. V (1965) § 45-723. Section 45-724 provides that “Where no price or amount is paid or required to be paid * * * the consideration for the deed to such property shall, for purposes of the tax imposed by this subchapter, be construed to be the fair…