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1994. True Oil’s 1994 return also contained schedules showing
that after June 30, 1994, Jean True owned a zero percent share of
True Oil’s income, deductions, losses, credits, capital account,
and other items. Similarly, Belle Fourche’s Federal tax return
(Form 1120S) for 1994 contains a schedule of changes in
ownership; that schedule showed that Jean True owned no Belle
Fourche stock after June 30, 1994.
The amount of the payment Jean True received on the payment
date (September 30, 1994) in exchange for her interest in a True
company was equal to the formula price of that interest as
determined under the corresponding buy-sell agreement. The
parties agree that the prices of Jean True’s interests as
determined under the buy-sell agreements, and the amounts
received by Jean True on the payment date in exchange for those
interests, were as shown in the following table:
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