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postulated reduction in value caused thereby would, as respondent
correctly observes, stem from the balkanization of decedent’s
interest in SSE among multiple beneficiaries. If the Redemption
Agreement were to be interpreted to require redemption of only
the voting shares, the Redemption Agreement would essentially
grant to the Foundation only decedent’s equity interest plus a
“term interest” in voting control, while simultaneously passing
the “remainder interest” in voting control over SSE to other
beneficiaries. Yet decedent’s interest would nonetheless pass in
its entirety. Decedent would have controlled SSE at his death
and would have through his estate plan passed that control first
to the Foundation and then to his descendants. Such is a
situation where value is divided, not destroyed. We therefore
conclude that the existence of the Redemption Agreement had no
effect on the value of decedent’s interest in SSE for gross
estate purposes.
We are equally satisfied that neither the 1992 Trust nor the
corporate bylaws constitute a relevant restriction to be taken
into account in valuing the gross estate. As regards the 1992
Trust, case law indicates that restrictions contained in a
revocable trust becoming irrevocable at death and essentially
functioning as an instrument of transfer are to be ignored in
making estate tax valuations. See Citizens Bank & Trust Co. v.
Commissioner, 839 F.2d 1249, 1251-1252 (7th Cir. 1988), affg. an
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