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Case: Dennis M. Sammarone vs.
SUPREME COURT RULES TRANSFER OF TITLE Dear Clients and Friends: On June 5, 2008,in the case of Shotmeyer, et al v. New Jersey Realty Title Insurance Company, the Supreme Court of New Jersey reversed the Appellate Division (Supreme Court, A-125 Sept. Term 2006, decided June 5, 2008) agreeing with the trial court, that title insurance coverage provided by a policy terminated upon the transfer of title, notwithstanding the fact that the new entity had the same composition of membership as its predecessor. The facts of the case are simply stated as follows: Through a general partnership controlled by them, Shotmeyer, et al purchased a tract of land (the "property") in 1981 which was transferred to a new entity, a limited partnership also controlled by Shotmeyer, as part of an estate-planning program in 1991 and 1992. In 2001, Shotmeyer discovered the property was smaller than believed and filed a claim with the title company that insured the 1981 purchase. The title company declined coverage on the basis that the real party in interest, the insured, had transferred title, and therefore there were no further obligations on the part of the title company to provide coverage. The trial court agreed with the title company, but upon appeal, the Appellate Division reversed. The Appellate Division found that the Shotmeyers had never transferred their "beneficial interest" in the land and that both the general and limited partnerships were merely alter egos of the Shotmeyers. The Supreme Court noted that the limited partnership entity shielded the individual partners from personal liability as contrasted with the general partnership in which the general partners were personally liable. The Court also found significant the fact that the general partnership entity remained with respect to its business operations. It only conveyed the real estate in question to the limited partnership. The Court found "that this fact carries weight in analyzing whether the policy continues to offer coverage". Unfortunately for the Shotmeyers, what started out as an estate planning tool, the conveyance to a limited partnership, resulted in the release of the title insurance company from any obligation to insure title relative to the successor entity. Its claim against the title company, therefore, was denied. In this day and age when income taxes are substantial and ever-increasing, estate planning techniques are extremely important in attempting to preserve wealth and assets. Moreover, other tax deferral techniques such as Section 1031 tax free exchanges have enabled property owners to avoid the payment of taxes in a properly qualifying 1031 Exchange. However, these techniques in many instances have required transitioning of existing entities to new entities in order to maximize the estate planning and 1031 tax saving opportunities. As the Supreme Court has now held, this may jeopardize existing title insurance coverage, thereby relieving title companies of their title coverage obligations in the event of post-closing claims. However, there are mechanisms including title insurance endorsements that can be procured that will prevent termination of coverage in the event of subsequent transfer of title:
In conclusion, it is extremely important that sellers and buyers of real estate retain competent real estate counsel to analyze for them any potential pit falls of a discontinuation of title insurance based upon their post-closing conveyance plans, so as to provide them with the best continuity of coverage available. In the meanwhile, let us hope that the New Jersey State Legislature will intervene to cure some of the potential inequities that may have arisen in connection with transfers for nominal consideration in the context of estate planning and tax free exchanges. Should you have any questions with regard to the above in general or as specifically applied to your particular situation, please feel free to contact Arnold D. Litt, Esq. at 201-498-8520 (direct line), or via e-mail at Alitt@hertenburstein.com or Susan M. Marra, Esq. at 201-498-8521 (direct line) or via e-mail at Smarra@hertenburstein.com.
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