[WSBARP] REET Question

[Paul Okner]

A REET question for all those who care to consider it:

Approximately 40 years ago, buyer purchased an operating company and
underlying (Seattle) real property from his parents in a stock sale.  He
ran the business, paid all the taxes, etc in the intervening time, and is
now looking to sell the real property.

Title company now realizes title to the real property was not owned by the
corporation all along, as assumed by buyers, but rather was still in the
name of the individual parents.  Of course they've passed.  Title company
now wants QCDs from a long list of descendants/heirs, and miraculously all
these folks are available and willing to sign.

So the last hurdle seems to be the DOR.  Client wants to rely on WAC
458-61A-215(1) and state that this is really just clearing up title, as all
parties believed, and will sign a supplement to the REETA stating, that the
property was always believed to be owned by the corporation.  My question
is, will DOR go for this, given the amount of time that's elapsed?

Thanks for your thoughts.

-Paul Okner
*Fremont Law Group PLLC*
3429 Fremont Pl. N.,  Suite 305
Seattle, WA 98103
(206) 399 - 1922

**Please note new mailing address above - Effective as of August 1, 2020**
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