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this theory. Patricia Low consistently acted as if she owned 100
percent of the agency as shown by the New Jersey inheritance tax
return, the Federal estate tax return, the agency's Federal
corporate tax returns, and her Federal individual income tax
returns. Although her actions after her mother's death do not
reflect on decedent's intent, they do reflect on Patricia Low's
credibility. Contrary to her testimony at trial, we find it
implausible that Patricia Low, an experienced business person,
never noticed that numerous tax returns, all signed under the
penalties of perjury, listed her as the sole owner of the agency.
Patricia Low reported and paid income tax on 100 percent of the
agency's income after her mother's death.6 "We know of no rule
that uncontradicted testimony must be accepted by a court finding
the facts, particularly where, as here, the testimony is given by
interested parties." Wood v. Commissioner, 338 F.2d 602, 605
(9th Cir. 1964), affg. 41 T.C. 593 (1964). We find it highly
unlikely that in the will and codicil decedent intended to give
to her daughter merely an option to buy agency stock.
Nor do we believe that decedent would have wanted her
daughter to have the stock subject to a charge to make the
installment payments. A charge would mean that if Patricia Low
failed to make the installment payments, she would, nevertheless,
still own the stock. Her father's only recourse would be to go
6 The agency was an S corporation.
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