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From April 1950 until January 25, 1982, decedent owned the
majority of common stock in SOAI, a closely held corporation.
SOAI was taxed as a regular or C corporation during the period
1980 to 1982. In 1960, after a 5-for-1 stock split, decedent
owned 850 of the 990 outstanding shares of SOAI. The other two
shareholders were decedent's wife with 5 shares, and Mr. James C.
Hull, an unrelated party, with 135 shares. From 1960 to December
1977, decedent transferred by gift 366 shares of stock in SOAI to
John Cidulka. Decedent retained 448 shares. Prior to 1977, 176
shares were acquired by SOAI and held by SOAI as treasury stock.
During the period 1960 to December 1977, decedent made annual
gifts of common stock varying from 3 to 10 shares to both John
Cidulka and Charlesa Cidulka. On the same days that Charlesa
Cidulka received stock as a gift from decedent, these same shares
were reissued to John Cidulka. Charlesa Cidulka never retained
the ownership of the shares of stock she received from decedent.
The stock transfer record indicates that on 14 different
occasions during the period 1963 through 1982 Charlesa Cidulka
received shares from decedent and transferred them to John
Cidulka on the same day.
On October 14, 1979, decedent transferred his 448 shares in
SOAI to the Bank of Indiana, trustee of the Joseph Cidulka
Revocable Trust (the revocable trust). The Joseph Cidulka
revocable trust agreement (the revocable trust agreement) was
dated September 28, 1979. In article 8 of the revocable trust
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