- 16 - Petitioner argues that, like the accounts receivable in Steffen, the source-attorney fees provision in the 1973 agreement was a financing arrangement by which future CSB fees would be used to redeem a retiring or deceased shareholder’s stock. We disagree. The $5 million payment was for both decedent’s CSB stock and any claims for work in process; in Steffen, we found that the corporation paid the taxpayer solely for his stock. Unlike Steffen, CSB and decedent did not intend to measure the value of decedent’s CSB stock solely by the amount of the insurance payment. 3. Erickson and Estate of Bette Petitioner relies on Erickson v. Commissioner, 56 T.C. at 1123-1124, and Estate of Bette v. Commissioner, T.C. Memo. 1977- 404, because in those cases the parties to stock redemption agreements included unpaid profits in measuring the value of the stock. Petitioner's reliance is misplaced. Unlike the agreement in the instant case, the written agreements in Erickson and Estate of Bette were solely stock redemption agreements. Here, as we have stated, the agreement provided for payment not only to redeem stock, but also for any claims to cases or work in process. C. CSB's Ownership of Work in Process Petitioner asserts that, under California law, work in process is a corporate asset and that shareholders do not ownPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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