Transfer Pricing Among Related Businesses - Kirkpatrick Associates, Incorporated

Richard (Rick) Kirkpatrick Sr. started Columbus Realty, Inc., a real estate firm, about 40 years ago. His personality and honesty made this undertaking a success. When his eldest son, John Kirkpatrick, graduated with an engineering degree. Kirkpatrick Sr. incorporated K & S Construction Company and put John in charge. Forty percent of the stock was given to John, and 60% was deposited with Kirkpatrick Associates, Incorporated, which Kirkpatrick Sr. controlled 100%. Having intimate knowledge of the housing market, Kirkpatrick Sr. suggested, and John agreed, that the construction company should concentrate on custom designed and built houses in the price range of( $100,000 to $200,000.) John Kirkpatrick's technical knowledge and imagination made the construction company a success.

Kirkpatrick Sr.'s second son, Court, received a degree in architecture but upon graduation was not ready to enter employment. Upon the suggestion of several friends and the family, Court Kirkpatrick continued with his education and pursued an MBA degree. During this study, and because of a special project he was assigned, he became interested in the development of living complexes around shopping centers. In this project, both the Living complex and the shopping center were designed with a continental motif. Further research convinced him that this project would not only be feasible but also very profitable. He discussed his idea and all the information he had gathered with his father, who agreed that this kind of design seemed to be the upcoming style. Upon Court's graduation, the Columbus Rental Company was incorporated with the same stock arrangement as with the K & S Construction Company.