Gottfried, Inc. v. Department of Revenue

This is a real estate transfer tax case. The Tax Appeals Commission (TAC) assessed a transfer fee when Gottfried, Inc., dissolved and conveyed its real estate to Jerome Gottfried, sole shareholder. The trial court reversed the TAC’s determination. It found that the tax exemption for trustee-to-beneficiary transfers applies to corporation-to-stockholder transfers undertaken in the course of corporate liquidation. We reverse and hold that the conveyance from Gottfried, Inc., trustee, to Jerome Gottfried was made for actual consideration and therefore does not fall within the ambit of any…