[WSBARP] REET Question

[Bryce Dille]

When they got their tax statement who showed as taxpayer the parents or the corporation?

From: wsbarp-bounces at lists.wsbarppt.com <wsbarp-bounces at lists.wsbarppt.com> On Behalf Of Paul Okner
Sent: Tuesday, September 22, 2020 12:16 PM
To: WSBA Real Property Listserv <WSBARP at lists.wsbarppt.com>
Subject: [WSBARP] REET Question

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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