Redemption Agreement Transferring Stock to Business Associate Was Not 'Testamentary Device'; 2d Cir. Reverses TC.

The Tax AdviserVol. 29 Nbr. 11, November 1998

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Redemption Agreement Transferring Stock to Business Associate Was Not 'Testamentary Device'; 2d Cir. Reverses TC.

In 1934, G founded the G Corporation. P became a G shareholder in 1949 and ultimately served on its board of directors. In 1960, G and P signed a redemption agreement restricting their rights to dispose of their stock.

G wanted S, an unrelated company officer, to own and manage the company after G's death. In 1987, G, P and S met with G's attorney, and they discussed G's intent to pass his stock on to S; at the same time, they discussed the redemption of some of G's stock at his death to pay estate taxes. In July 1987, G signed ...

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