Seaberg v. Specific Properties CA5

California Court of Appeal·Decided August 31, 2026·No. F090185·Unpublished

Opinion

Filed 8/31/26 Seaberg v. Specific Properties CA5

NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS

California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or or dered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIFTH APPELLATE DISTRICT

JEFFREY SEABERG, F090185

Plaintiff, Cross-defendant and Appellant, (Super. Ct. No. 20CECG00012)

v.

SPECIFIC PROPERTIES, LLC et al., OPINION

Defendants, Cross-complainants and Respondents.

APPEAL from a judgment of the Superior Court of Fresno County. Kristi Culver Kapetan, Judge.

Richard M. Watts, Jr., for Plaintiff, Cross-defendant and Appellant. LaMontagne & Amador and Eric A. Amador for Defendants, Cross-complainants and Respondents John S. Foggy, Robert E. Ellis and Stephen D. Long.

No appearance for Defendant, Cross-complainant and Respondent Specific Properties, LLC.

-ooOoo-

This appeal arises from a complaint that appellant Jeffrey Seaberg filed against respondent Specific Properties, LLC (Specific Properties). Seaberg claimed that a part owner of Specific Properties, respondent John Foggy, received excess distributions from Specific Properties’ accounts. Underlying the disputed distributions were a series of real estate transactions proposed and driven by Foggy that sought to defer taxes owed on multiple property sales involving multiple entities. Seaberg insisted that under these transactions, Specific Properties owned a property that Foggy then wrongly treated as his own. After a bench trial, judgment was entered denying Seaberg’s claims. For the reasons set forth below, we affirm.

FACTUAL AND PROCEDURAL BACKGROUND In the 1990’s, Foggy, respondent Robert Ellis, and Seaberg formed a partnership that became known as Specific Properties. Foggy was engaged in commercial real estate transactions. Ellis was a real estate broker. Seaberg was a contractor. Each member was granted one-third share of ownership in the company.

Foggy appears to have been the most successful of the three at the start of the business. When the group found their first property, Foggy loaned Seaberg the needed funds, which were paid back from the rents obtained on the property. Similar loans were made to Seaberg and Ellis as additional properties were found. Notably, most of these loans were done without formal documentation.1 In fact, the members of Specific Properties typically operated informally, agreeing to take actions without following the formal procedures outlined in their operating agreement or even recording those agreements.

In addition to Specific Properties, Foggy was the sole owner of another company with real estate holdings, W&F Building Maintenance Co. (W&F). Relevant to this case,

1 The record does show that Foggy took a deed of trust on Seaberg’s home with respect to one of these loans.

W&F owned a property in Sacramento called the Warehouse Property. Also relevant to this case is respondent Stephen Long. Long owned a management company and provided financial and accounting services to Foggy. Long also had a trust fund that he used to purchase commercial properties.

In 2013, Specific Properties owned three commercial buildings, known as Abby/Blackstone, Abby, and Kern Street. Long, through his trust, owned an interest in two of these properties, including a 25 percent interest in Kern Street. Kern Street was purchased in 2006 for $750,000. In general, Foggy, Ellis, Seaberg, and Long received equal payments derived from the rents earned on their shared properties.

In late 2013, Foggy, through W&F, sold the Warehouse Property for roughly $3.2 million. To defer the capital gains taxes associated with the sale, Foggy sought to complete what is known as a 1031 exchange, a like-kind property exchange named after 26 United States Code section 1031. Under such an exchange, a seller must designate a replacement property within 45 days and close on that property within 180 days, as well as meet other requirements.2 Through Ellis, Foggy identified a property known as West Shaw as his main candidate for the 1031 exchange. However, this property had 17 owners, some of whom lived outside of the country. Therefore, as a backup and within the 45-day window, Foggy designated both West Shaw and Specific Properties’ Kern Street as potential exchange targets.

Foggy entered into a purchase agreement for West Shaw that allowed him to assign the agreement to another. At the time, he intended to assign the agreement to W&F to effectuate the 1031 exchange. However, trouble contacting the out-of-country owners created a risk the transaction would not close within the 180-day window. Not

2 Seaberg’s unopposed request for judicial notice filed on December 30, 2025, is granted.

wanting to lose the West Shaw purchase, Foggy called Seaberg to discuss an arrangement to preserve that purchase and the 1031 exchange.

According to Foggy, the idea was to purchase Kern Street from Specific Properties under a 1031 exchange and then, when the final signatures were obtained on the West Shaw purchase, to reverse the Kern Street sale so that Foggy could complete the 1031 exchange for West Shaw. Seaberg testified that he was concerned about the plan because selling Kern Street would cause Specific Properties to lose an asset and its associated rents without having a backup plan. This caused Seaberg to draft a letter on December 28, 2013, detailing the terms of the proposed agreement.

The letter explained there would be a “temporary sale” of Kern Street to W&F due to time restrains on “another property” not being able to close. When that property was ready, Kern Street would “be put back in namesake as per before sale.” Under the agreement, Foggy would “cover all costs associated with this transaction and guarantee property will be reversed to original holding as per before sale,” as well as cover any additional increases in property taxes “each year along with prorated increases assessed compared to taxes prior to this transaction.” Finally, all rents from Kern Street “will continue to go to Specific Properties and disbursements will continue as they have before this transaction took place.” Seaberg, as well as the others involved, knew the reference to “another property” was to West Shaw and expected that Foggy would purchase West Shaw after undoing the Kern Street purchase.

A few days after Foggy, Ellis, and Long, whose trust owned 25 percent of Kern Street, received Seaberg’s letter, Foggy called again with another issue. Having been told that the swap back should not occur in the same year as the purchase, Foggy suggested that Specific Properties purchase West Shaw in its own 1031 exchange and then later exchange West Shaw for Kern Street. This would also allow Specific Properties to defer taxes on the sale of Kern Street. Seaberg testified he knew there was still a plan to swap back, but felt this new plan was acceptable because if all else fell apart, Specific

Properties held a good building. Based on his comfort level, Seaberg did not memorialize this second conversation.

Some agreement, however, was reached, and Foggy, through W&F, purchased Kern Street for $3.2 million in early January 2014. Foggy did not receive a discount based on his ownership stake, and there was no negotiation over the price, which aligned with the figure for the Warehouse Property sale. Foggy then assigned his right to purchase West Shaw to Specific Properties and Long’s trust. By February 28, 2014, Specific Properties and Long’s trust closed on the purchase of West Shaw for roughly $3.38 million. Foggy provided roughly $150,000 needed to fill the gap between the funds obtained from the Kern Street sale and the purchase price.

The planned swap of Kern Street and West Shaw did not materialize, however.

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