Federal Transfer Tax Consequences of Estate Freezes : Scheduled for a Hearing Before the Committee On Ways And Means On April 24, 1990 Jcs-13-90
Federal Transfer Tax Consequences of Estate Freezes : Scheduled for a Hearing Before the Committee On Ways And Means On April 24, 1990 Jcs-13-90
United States. Congress. Joint Committee On Taxation
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20.2031-2(h). 39 See Rev. Rul. 59-60, 1959-1 C.B. 237, 243 (option price "usually accepted as fair market value for estate tax purposes"). ■»" See, e.g., Weil v. Commissioner, 22 T.C. 1267, 1273-74 (1954), acq., 1955-2 C.B. 10. "i See Saint Louis County Bank v. United States, 674 F.2d 1207 (8th Cir. 1982). *^ See Littick v. Commissioner, 31 T.C. 181, 187 (1958), acq., 1959-2 C.B. 5, acq., 1984-2 C.B. 1 (in result). *^See Wilson v. Bowers, 57 F.2d 682 (2d Cir. 1932) (buy-sell agreement that bind...s the estate caps the value of corporate stock even if the holder of the option does not exercise the option and instead obtains the interest under the will). •'* See Estate of Bischoff v. Commissioner, 69 T.C. 32 (1977) (maintenance of control is business purpose even if the interest being sold is a limited partnership interest in a holding company). ■•^ In Littick the decedent, who had contracted a terminal illness entered into a fixed-price buy-sell agreement with his brothers one year prior to death.
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