Comp.Codes R. & Regs., tit. 20, § 526.6(d)(1)(v) (2010) (declaring that the definition of a retail sale for sales and use tax purposes excludes "[the contribution of property to a partnership in consideration for a partnership interest therein" and stating that "[the transfers described in this paragraph between ... corporations and stockholders, are excluded from the definition of 'retail sale' because while the form of ownership of the property is changed, there is a continuity of interest in the property transferred"); Ohio Rev.Code Ann. § 5751.01(F)(2)(0 ) (LexisNexis 2010) (defining "gross receipts" for purposes of the Ohio commercial activity tax to exclude "[clontri-butions to capital"). 2 . See, e.g., Hogan v. Adams Prop. Assocs., Inc., 253 Va. 217, 482 S.E.2d 805, 807 (1997) (<HOLDING>); Wolter v. Wis. Dep't of Revenue, 231 Wis.2d
holding that transfer of property to llc involved no consideration for state conveyance tax purposes because it was a unilateral act and not the result of a bargainedfor exchange holding transfer of legal title to property as a capital contribution to llc was in exchange for valuable consideration and constituted a sale of the property recognizing satisfaction of a valid debt as adequate consideration in a transfer of real property holding transfer of capital accounts from a limited partnership to a llc was valuable consideration for purposes of imposing state real estate transfer fee because the members received new rights and privileges holding that it is not a collusive transaction when valuable consideration is paid to transfer a debt to a bona fide purchaser even if the transfer was for the purpose of invoking diversity jurisdiction