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those dates Jean True became obligated to sell, and her sons
became obligated to buy, her interests in the 22 True companies.
2. From and after June 30, 1994, the 22 True companies
considered the income and expenses associated with the interests
sold by Jean True to belong to the sons, not to Jean True.
Moreover, the True companies filed their Federal tax returns
consistently with this observation.
3. Although the reissuance of some stock certificates to
reflect the change in ownership of Jean True’s stock was
authorized on September 29, 1994, the minutes of the board
meetings concerning this action refer to “the transfer of the
shares formerly owned” by Jean True, and state that “appropriate
action should be taken * * * to accept and acknowledge the
transfer of ownership that occurred effective June 30, 1994".
(Emphasis added.) Similarly, the accompanying board resolutions
discuss “the sale and transfer effective June 30, 1994" of “the
shares previously held” by Jean True. (Emphasis added.)87
4. The partnership buy-sell agreements provided that the
price for a partnership interest owned by Jean True was equal to
87As noted supra p. 299, petitioners argue that Jean True’s
sales were completed for tax purposes on Sept. 20, 1994. It is
not clear why petitioners chose this date. It appears that a
formal closing of Jean True’s purchase (from Dave True) of some
of the stock she ultimately sold to her sons was held on or
around that date. However, the minutes of the Sept. 20, 1994,
board meetings authorizing the reissuance of Dave True’s stock to
Jean True treat June 4, 1994 (the date of Dave True’s death), as
the effective date of the transfer of ownership of that stock to
Jean True.
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