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transactions in the record is neutralized by the fact that many
of the transactions took place between parties that were hardly
related or unrelated and who had fiduciary obligations to obtain
the best price. We view the variety of relationships among the
shareholders in Huber as a positive indicator of the existence of
arm’s-length sales.
IV. Compulsion
Respondent argues that the sales of the shares from the
Brown estate and the Foster trust were under “compulsion” and
thus not representative of arm’s-length sales. Respondent relies
on Acme Mills, Inc. v. Commissioner, 6 B.T.A. 1065 (1927).
However, in Acme Mills, the Court found that the taxpayers were
under “very decided pressure” from their creditors to sell the
property in order to settle creditor claims. Id. at 1067. There
was no such pressure here. The Brown estate sold its shares to
pay the estate tax; there was no immediate time constraint. The
executors had been planning for a number of years to sell the
shares and were waiting for their tax obligations to be resolved
so that they knew how much money was needed. Once a valuation of
the estate was agreed upon with the IRS, the estate had 5 months
to pay the liability. The estate was able to sell the shares in
just 1 month. Mr. Seely testified that he felt no pressure to
sell the estate’s shares and that he raised the necessary funds
to pay the estate tax within a matter of weeks. We fail to see
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