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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.
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