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in and around Fayette County, Alabama. In April 1949,
petitioner’s grandfather died and left petitioner, his only
grandchild, a 25-percent interest in all that he owned. Among
the grandfather’s possessions was an interest in more than 9,000
acres spread over numerous parcels in and around Fayette County,
Alabama (the land), and stock (the bank stock) in three
rural Alabama banks-–the Bank of Parish, the Bank of Berry, and
the Bank of Carbon Hill (the banks).
Prior to 1957, petitioner’s father gave petitioner an
additional 25-percent interest in the land, thereby increasing
petitioner’s ownership interest to 50 percent. As described in
more detail below, on January 3, 1957, petitioner and his father
leased the land to Hiwassee Land Co. (Hiwassee) under a 66-year
timber lease. On June 2, 1965, petitioner’s father died, leaving
all his property–-including his 50-percent interest in the land
and an undisclosed amount of stock in the banks--to petitioner’s
mother. Petitioner’s mother died shortly thereafter, devising to
petitioner her 50-percent interest in the land and the bank
stock. Petitioner then owned the entire interest in the land,
subject to Hiwassee’s leasehold interest. Petitioner also owned
more than 50 percent of the common stock of the banks, of which
he was then president.1
1 The record does not specify when petitioner first became
president of the banks.
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Last modified: May 25, 2011