American Properties Co., G.P. v. The Welfont Group, LLC

CourtDistrict Court, W.D. Tennessee
DecidedSeptember 10, 2025
Docket2:22-cv-02329
StatusUnknown

This text of American Properties Co., G.P. v. The Welfont Group, LLC (American Properties Co., G.P. v. The Welfont Group, LLC) is published on Counsel Stack Legal Research, covering District Court, W.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
American Properties Co., G.P. v. The Welfont Group, LLC, (W.D. Tenn. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TENNESSEE WESTERN DIVISION

AMERICAN PROPERTIES, CO. G.P., ) ) Plaintiff, ) ) v. ) No. 2:22-cv-02329-SHL-tmp ) THE WELFONT GROUP, LLC, ) TAX APPRAISAL GROUP, LLC, ) and LYNDA SCULL, ) ) Defendants. )

ORDER GRANTING IN PART AND DENYING IN PART SUPPLEMENTAL MOTION FOR DEFAULT JUDGMENT

Before the Court is Plaintiff American Properties, Co. G.P.’s Supplemental Motion for Default Judgment (ECF No. 70), filed June 23, 2025. On October 12, 2022, default was granted as to Defendants The Welfont Group, LLC (“Welfont”), Tax Appraisal Group, LLC (“TAG”), and Lynda Scull (together, “Defendants”)1, following multiple warnings of their need to participate in this litigation. (ECF No. 40 (“Clerk’s Entry of Default”).) On September 19, 2023, a default judgment was granted, again based on those same defendants’ failure to participate. (ECF No. 66.) However, the amount of the judgment could not be ascertained because of an appeal pending at the time before the Internal Revenue Services (“IRS”). (See id.) Now, Plaintiff seeks a default judgment in the amount of $7,107,296, comprised of $1,751,824 in actual damages, $5,255,472 in treble damages pursuant to the Tennessee Consumer Protection Act, Tenn. Code Ann. § 47-18-101 et seq. (“TCPA”), and $100,000 in

1 Two additional defendants did appear, and judgment has been entered as to them. (See ECF No. 31.) attorney’s fees pursuant to the TCPA, against Defendants jointly and severally. (ECF No. 70 at PageID 469.) Defendants did not respond. For the following reasons, the Motion is GRANTED IN PART and DENIED IN PART. BACKGROUND2

In July 2018, Plaintiff was looking to sell a piece of real property (“the Property”) in Memphis, Tennessee, when Welfont presented an unconventional offer. (ECF No. 1 at PageID 7.) Plaintiff had been asking $3,995,000 for the Property, but Welfont had something else in mind. (Id. at PageID 6.) If Plaintiff could get a higher-value appraisal that the IRS would accept—a “Qualified Appraisal”—and then sell the Property to a qualified charitable organization for below that amount, Welfont explained, Plaintiff would receive a substantial tax deduction worth the difference between the two. (Id.) Plaintiff agreed, and so, to effectuate the sale, the Parties entered into a Real Estate Purchase Agreement. (Id. at PageID 9.) According to the Agreement, Welfont would obtain a Qualified Appraisal of the Property of approximately

$5,388,000 and Plaintiff would sell the Property to a qualified charitable organization for $2,000,000.3 (Id.) Welfont would also receive a commission of $62,403. (Id.) Welfont then introduced Plaintiff to TAG, which contracted with Plaintiff to provide a Qualified Appraisal of the Property for a $1,000 fee. (Id. at PageID 9.) Lynda Scull, TAG’s manager, exercised complete dominion and control over TAG’s finances, policies, and business practices. (Id. at PageID 20.) As Plaintiff would later discover, not only was TAG “grossly

2 These facts are contained in Plaintiff’s complaint, and are accepted as true by virtue of Defendants’ default. See Antoine v. Atlas Turner, Inc., 66 F.3d 105, 110–11 (6th Cir. 1995).

3 The Purchase Agreement was later amended to increase the purchase price to $2,160,000. (Id.) undercapitalized,” diverting its earnings and assets directly to Scull, but its appraisal was not even an actual Qualified Appraisal. (Id. at 12, 20.) Relying on the three Defendants’ promises and appraisal, Plaintiff sold the Property to a charitable organization in May 2019 for $2,160,000, and claimed a deduction of $2,595,000 on

its 2019 tax return. (Id. at PageID 11.) Unbeknownst to Plaintiff, however, on the same day it sold the Property, an alter ego of Welfont purchased the Property from the charity for only $2,650,000—radically undermining the appraised value of $5,388,000. (Id.) The IRS noticed. In a later audit of Plaintiff’s 2019 tax return, the IRS found that (1) the appraisal Plaintiff relied on was not a Qualified Appraisal; (2) the Property had a fair market value of $2,650,000, lower than Plaintiff expected; (3) Plaintiff’s deduction contribution from the sale of the Property was reduced from $2,595,000 to a mere $490,000; and (4) Plaintiff owed at least $571,765 in taxes, fees, expenses, and costs. (Id. at PageID 11–13.) Plaintiff filed suit against Defendants, alleging (1) breach of contract; (2) negligent misrepresentation; (3) fraud or constructive fraud; (4) negligence; (5) violation of the TCPA; (6)

veil piercing; and (7) civil conspiracy. (ECF No. 1.) Despite service, Defendants never appeared in this action. Because of Defendants’ lack of appearance, the Clerk entered default (ECF No. 40), and Plaintiff filed its motion for default judgment (ECF No. 43). Based on Plaintiff’s motion and a hearing on January 19, 2023, the Court granted in part a default judgment against Defendants, finding them liable to Plaintiff for all claims. (ECF No. 66.) As discussed at the hearing, the damages resulting from Defendants’ actions equal the tax liability imposed on Plaintiff. (See id.) However, at the time of the hearing, Plaintiff was appealing that tax liability, and so the Court held in abeyance the calculation of damages for the default judgment. (See id.) A year and a half passed. Then, after the Court requested on May 12, 2025, to be apprised of the status of the administrative appeal (ECF No. 67), Plaintiff provided an update a week later (ECF No. 68). The IRS had issued a Notice of Final Partnership Adjustment on August 28, 2024, determining that Plaintiff owed underpayments of $1,088,344 and $217,669 in penalties as of that date. (Id.

at PageID 454; see also ECF No. 68-1.) Because Plaintiff disagreed with some of the IRS’ methodologies and calculations, it filed a Petition for Readjustment in the United States Tax Court. (ECF No. 68 at PageID 454–55.) Instead of waiting for resolution in the Tax Court, however, given the length of litigation, the Court ordered Plaintiff to file a supplemental motion for default judgment.4 (ECF No. 69.) Plaintiff did so on June 23, 2025 (see ECF No. 70), and now the Motion is ripe for review. ANALYSIS

When a party defaults, it “effectively admits all well-pleaded allegations in the Complaint.” BMO Bank, N.A. v. Len Snyder Trucking, LLC, No. 1:24-CV-01089-STA-jay, 2024 WL 4469114, at *1 (W.D. Tenn. Sept. 16, 2024), report and recommendation adopted, No. 1:24-CV-01089-STA-jay, 2024 WL 4467532 (W.D. Tenn. Oct. 10, 2024) (citing Visioneering Constr. v. U.S. Fid. and Guar., 661 F.2d 119, 124 (6th Cir. 1981)). However, “‘a default admits only the defendant’s liability’ but ‘the amount of damages must be proved.’” New London Tobacco Mkt., Inc. v. Ky. Fuel Corp., 44 F.4th 393, 403 (6th Cir. 2022) (quoting Antoine v. Atlas Turner, Inc., 66 F.3d 105, 110 (6th Cir. 1995)). Plaintiff seeks damages for each count in the complaint, as discussed below.

4 The Court instructed Plaintiff that, should the Tax Court Appeal result in a favorable outcome or a change in circumstances, Plaintiff could address that issue at a later point. (ECF No. 69 at PageID 466.) I. Contract Damages

First, the Court found Welfont and TAG liable for breach of two contracts—the Purchase Agreement with Welfont, and the Contract with TAG. (ECF No. 66 at PageID 448–49.) In Tennessee, the default measure of expectation damages is “awarding the party the benefit of its bargain.” Mueller Brass Co. v. Crompton, No. 2:20-CV-2496-SHL-ATC, 2024 WL 2303953, at *3 (W.D. Tenn.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Webb v. County Board of Education
471 U.S. 234 (Supreme Court, 1985)
Aundrey MEALS Ex Rel. William MEALS v. FORD MOTOR COMPANY
417 S.W.3d 414 (Tennessee Supreme Court, 2013)
Jean Dedmon v. Debbie Steelman
535 S.W.3d 431 (Tennessee Supreme Court, 2017)
Turnage v. Oldham
346 F. Supp. 3d 1141 (W.D. Tennessee, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
American Properties Co., G.P. v. The Welfont Group, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/american-properties-co-gp-v-the-welfont-group-llc-tnwd-2025.