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family ownership and control of a corporation has been recognized in
certain cases as a legitimate business purpose. See Estate of
Bischoff v. Commissioner, 69 T.C. at 39-40; Estate of Littick v.
Commissioner, 31 T.C. 181, 187 (1958); Estate of Lauder v.
Commissioner, supra.
Petitioners also assert that the Buy-Sell Agreement was
intended to prevent Ronald from leaving CamVic. Respondent contends
that the evidence fails to demonstrate that Ronald was uniquely
qualified for any of his responsibilities at CamVic such that there
was a bona fide business need to retain him.
Ronald began working for CamVic in 1959. Ronald testified that
he supervised the construction of Dina Terrace, and he drew the
plans for and supervised the construction of Dina Tower. When these
apartments were completed, Ronald managed the properties for CamVic.
Moreover, Ronald testified that he and decedent had conflicting
business philosophies. Ronald stated that he believed CamVic should
build and manage properties, whereas decedent had a build and sell
philosophy. Ronald further testified that decedent had previously
made impulsive business decisions which Ronald believed were to the
detriment of CamVic. For instance, Ronald testified that decedent
had constructed a golf course on land unsuitable for that purpose,
purchased a mobile home park in a flood plain at a price above the
land's appraised value, and insisted on purchasing nearly 4 acres of
land for a car wash when a half acre was sufficient. Ronald stated
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