Howes v. Tax Appeals Tribunal

The facts in this case are not in dispute. In April 1977, petitioner purchased real property on West 9th Street in New York City through a wholly owned corporation, Counsel Properties, Inc. After the purchase, the corporation was liquidated and the property, an apartment building, was distributed to petitioner, who used one of the apartments as his personal residence and rented the others. Petitioner then “contributed” the rental portion of the building to Counsel Properties Company, a partnership consisting of petitioner and Suzette Hen*814nion, who subsequently married petitioner (hereinafter…