Cameron W. Bommer Revocable Trust, Ronald Bommer, Trustee - Page 23

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            the plain wording of the Buy-Sell Agreement leaves no question as to                        
            the unilateral authority that decedent possessed.  Decedent                                 
            singlehandedly could have altered the price-per-share clause, as                            
            well as any other terms of the agreement.                                                   
                  Ronald testified that the parties to the original agreement                           
            never intended that decedent should have the unilateral right to                            
            amend and that, in 1981 (6 years later), Ronald discovered this                             
            "error" in the agreement.  We cannot accept this explanation.  The                          
            evidence indicates that decedent was a man who liked to control his                         
            affairs.  In 1975, he was 62 years old and in good health.  The                             
            language of the agreement is clear.  It was signed in 1975 by                               
            decedent, Ronald, and Kenneth Hughes.  Mr. Hughes prepared the                              
            agreement and was also the trustee of the CWB Trust.  We have no                            
            doubt that decedent, Ronald, and the attorneys at Santen, Santen &                          
            Hughes recognized that the agreement gave decedent the authority to                         
            amend the agreement.  Under these circumstances, we need not, and do                        
            not, accept Ronald's self-serving and uncorroborated testimony that                         
            the 1981 change was simply a correction of a scrivener's error in                           
            the 1975 Buy-Sell Agreement.  See Tokarski v. Commissioner, 87 T.C.                         
            74, 77 (1986).                                                                              
                  Petitioners assert that the agreement is valid for estate tax                         
            purposes even if decedent had the power to change its terms.                                
            Petitioners contend that our decision in Estate of Bischoff v.                              
            Commissioner, 69 T.C. 32 (1977), supports their position.  In Estate                        
            of Bischoff v. Commissioner, supra at 42, we found that a                                   




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