595 Investors Ltd. Partnership v. Biderman

OPINION OF THE COURT

Edward H. Lehner, J.

The question posed by the motion and cross motion for *442summary judgment is whether the New York City Real Property Transfer Tax (RPTT) is applicable to plaintiffs syndication of limited partnership interests in itself when the plaintiff did not own any realty, but was the sole limited partner in a partnership that did. Under the facts presented herein, the sale by syndication to limited partners of more than a 50% interest in plaintiff constitutes a taxable conveyance under that statute.

FACTS

On September 3, 1986, 595 Madison Avenue Associates Limited…