- 296 - following companies: True Oil, Eighty-Eight Oil, True Ranches, Belle Fourche, and Black Hills Trucking. As a result of Dave True’s death on June 4, 1994, Jean True acquired part of the stock and partnership interests she ultimately sold to her sons. Dave True’s death triggered the buy-sell agreements and required Jean True and the sons to buy the interests formerly held by Dave True. The sales of stock triggered by Dave True’s death apparently were not formally closed until about September 20, 1994. Although the record does not establish precisely what happened on September 20, 1994, it appears that the reissuance of stock certificates to reflect the transfer of ownership from Dave True to Jean True and the sons was authorized on that date. However, the buy-sell agreements defined the effective date of these transfers as the date of Dave True’s death. Consistent with this definition, the minutes of the board meetings concerning the reissuance of Dave True’s stock treat Dave True’s death as the date ownership of the stock was transferred to Jean True and the sons.83 On a schedule attached to Jean True’s amended Federal gift tax return for 1994, Jean True reported the 1994 sales of her interests to her sons as gifts with a “Value at date of gift” of 83Respondent has not determined or otherwise asserted that any gift loans resulted from the sales triggered by Dave True’s death on June 4, 1994, even though some of those sales may not have been formally closed until Sept. 20, 1994.Page: Previous 286 287 288 289 290 291 292 293 294 295 296 297 298 299 300 301 302 303 304 305 Next
Last modified: May 25, 2011