Property Transfer Request Letter
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Business Negosyo tax letters Units Transfer Condominium Unit Property Transfer Letter
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June 25, 2010 RE: Ruling Request Real Property Transfer Tax FLR: 094901-021 Dear: This letter responds to your request, dated October 13, 2009, on behalf of (the “Taxpayer”), for a ruling that the transfer of two adjacent condominium units to be used as one unit should be treated as the transfer of an individual residential condominium unit for purposes of the New York City Real Property Transfer Tax (the “RPTT”).. The facts presented here closely resemble those in Gruber: the Condominium’s offering plan identified the space as separate units, and they were marketed and shown that way the units had never been used by residents as separate units the Taxpayer, at the time of purchase, arranged to combine the units, and the combination of the units was an integral part of the purchase the Sponsor agreed to combine the units according to detailed specifications set out in the Purchase Agreements the work to be done included removing walls, replacing the floor in one unit, removing a kitchen, and electrical and plumbing alterations the construction work was financed through the Escrow Agreement, funded by the H and W, and payments were made to the Sponsor in accordance with certain benchmarks and by ten days following the closing, the units were physically combined..
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