- 118 - circumstances mentioned above. Petitioners counter that they did not amend the formula when they amended the agreements for other reasons because they believed that the agreements produced a fair and reasonable price. On the contrary, we believe that petitioners did not alter the formula price because the sons would benefit (taxwise and pricewise) from leaving in place a formula transfer price that was as low as possible. h. Business Arrangements With True Children Fulfilled Dave True’s Testamentary Intent Dave True’s business arrangements with his children fulfilled his testamentary intent, as evidenced by his will and ancillary estate planning documents. At his death, Dave True’s estate plan provided equally for his children, except Tamma Hatten. Dave and Jean True amended their estate planning documents to delete any specific provisions for Tamma Hatten and her family after her withdrawal from the family businesses. The advancement language in Dave True’s appointment document explained that Tamma Hatten’s “potential inheritance” had been fully satisfied when his daughter severed her financial ties with the True companies. Since the 1970's, each of the True sons has managed one or more of the True companies. Hank True assumed responsibility for the oil and gas marketing, pipeline, and environmental cleanup businesses; Diemer True managed the trucking and tool supply companies; and David L. True ran the ranching and drillingPage: Previous 108 109 110 111 112 113 114 115 116 117 118 119 120 121 122 123 124 125 126 127 Next
Last modified: May 25, 2011