Petitioner, a limited partnership and commercial landlord, entered into a 1986 settlement agreement with one of its tenants in which it agreed to assign to the tenant, or the tenant's designee, a 2% interest in petitioner's distributions. The tenant designated respondent, and petitioner prepared and filed the documents necessary to effectuate an assignment of the 2% interest directly to respondent. It appears that respondent is a corporation that was formed and 100% owned...
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