Baumer v. United States

580 F.2d 871
CourtCourt of Appeals for the Fifth Circuit
DecidedSeptember 25, 1978
StatusPublished

This text of 580 F.2d 871 (Baumer v. United States) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Baumer v. United States, 580 F.2d 871 (5th Cir. 1978).

Opinion

based on the special facts of each case. No appellate court, no matter how ingenious, can devise a simple, mechanical formula which will reveal the “correct” characterization of the transaction at issue in every instance. As the Court held in Cumberland, “[i]t is for the trial court, upon consideration of the entire transaction, to determine the factual category in which a particular transaction belongs. Here as in the Court Holding Co. case we accept the ultimate findings of fact of the trial tribunal.” 70 S.Ct. at 282-83.

In the instant case, the district court concluded that the government’s Court Holding theory was “inapplicable to the factual situation presented in this case,” finding that the distribution of the option to Son occurred before a sale of the property was even contemplated,11 that Son was personally involved to a substantial extent in the development activity which led to the increased value of the Piedmont-Old Ivy properties,12 and that Son negotiated with Pope & Carter in his own behalf with respect to his interest in the properties.13 These findings must be accepted unless clearly erroneous. Hines v. United States, supra, 477 F.2d at 1071 n. II.14 Our review of the record convinces us that there is ample evidence to support the court’s factual determinations. We therefore affirm the court’s judgment that this transaction was not stricken by Court Holding’s selling virus.

In so holding we are not unaware of certain doubts raised by the government concerning the economic reality of the transactions between Corporation and Son. The government correctly notes that the corporation bore all the risks with respect to the zoning action, which was necessary to make the purchase a profitable venture. Son did not actually exercise his option and acquire title to the property until favorable zoning was obtained and the sale to Pope & Carter became a virtual certainty. Furthermore, Corporation actively participated in the negotiations with Pope & Carter which led to the sale of the Piedmont-Old Ivy properties. Son never expended a single cent on the transaction, either in acquiring the option or in exercising it. Indeed, the note Son gave Corporation as payment for the properties was modified shortly after its execution to allow a pass through to Corporation of Pope & Carter’s payments to Son. The government further argues that, as a matter of law, the options granted by Corporation to Son were merely continuing [872]*872offers to sell which did not transfer a present property interest to Son. Were this the case, no property interest would have been transferred from Corporation to Son until after the agreement with Pope & Carter was negotiated and virtually consummated by Corporation. To the extent Son participated in the negotiations before the sale from Father to Son, his activities would have been on behalf of Corporation since Son would have had no interest of his own. In such circumstances, a finding that the sale of Son’s interest to Pope & Carter’s assignee was made by Son, rather than by Corporation, would be difficult, if not impossible, to support.

The critical link in this chain of reasoning by the government is its legal argument that the option is invalid under state law for lack of consideration. We disagree. In Smith v. Wheeler, 283 Ga. 166, 210 S.E.2d 702 (1974), the Supreme Court of Georgia held that an option to buy real estate was binding on the optionor even though the optionee failed to deliver the one dollar recited in the contract as the sole consideration for the option. The Court reasoned that the recital to pay a nominal consideration gives rise to an implied promise to pay which can be enforced by the other party. The government attempts to distinguish Smith on the ground that the instant case involves an intra-family transaction while in Smith the Georgia Court was confronted with an arm’s-length agreement struck by unrelated individuals. We can discern no basis for such a distinction under state law. Related individuals are free to enter into binding contracts, and we have found no Georgia cases holding that different rules govern the validity and enforceability of a contract where related individuals are involved. Here the option agreement was formalized in writing and signed by both parties. Under Georgia law, the recitation of nominal consideration having been paid by the optionee is sufficient to bind the optionor.15

[873]*873Notwithstanding our rejection of the government’s legal position that a grant of an option by a closely held corporation to a shareholder for nominal consideration cannot transfer a property interest, we concede that the factors discussed by the government raise doubts concerning the district court’s factual characterization of the transaction.

Nonetheless, there is other evidence in the record which supports the district court’s findings and conclusions. Under the standard applied by this Court in Hines v. United States, supra, the critical factual question is whether Corporation “actively participated in the transaction that produced the income to be imputed.” 477 F.2d at 1069 (emphasis supplied). Application of this standard in the case at bar is complicated by the fact that both Son and Corporation had interests in the property. In the more typical situation, such as that presented in Hines, the entire property is transferred to the shareholder. In such a case, any participation by the corporation in negotiating the sale of the property after that property is distributed to the shareholder evidences a sale by the corporation, rather than the shareholder. Here, however, Corporation retained a one-half interest in the property. It is absurd to suggest that income may be imputed to the corporation simply because it negotiated with third parties concerning this disposition of its own interest in the property. Instead, the crucial question becomes whether the Corporation “actively participated” in the sale of Son’s share of the property. This is a question of fact, and proper deference must be given to the findings of the district court. The district court found in this regard that Father negotiated with Pope & Carter “on behalf of the Corporation” and that Son negotiated “on his own behalf.” See footnote 13 supra. This finding is itself supported by the record and is further supported by two subsidiary findings indicating the reality of Son’s interest in the property.

The court found that at the time the option was granted, Father and Son intended to use the property themselves “for a motel.” This finding, supported by evidence in the record, indicates that no sale of the property was contemplated when Son received the property interest reflected by the option. This, in turn, supports the conclusion that the option was not merely a subterfuge designed to conceal Corporation’s subsequent sale of the entire property, but instead was intended to pass an interest to Son which Son, and not Corporation, later disposed of in the sale to Pope & Carter.

The court’s determination that Son, rather than Corporation, negotiated with respect to Son’s interest in the property is further supported by evidence that Son was personally involved to a substantial extent in the development activity which led to the increased value of the properties.

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Bluebook (online)
580 F.2d 871, Counsel Stack Legal Research, https://law.counselstack.com/opinion/baumer-v-united-states-ca5-1978.