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most of the relevant years, the applications were granted at
least in part, but on one occasion the application was denied.
Although the taxpayer in Roebling relied only upon section
302(b)(1) to support her contention that each of the redemptions
qualified as a sale or exchange under section 302(a), she argued
that the redemptions were integrated steps in a firm and fixed
plan to redeem all of the preferred stock and that the
redemptions in the aggregate resulted in a meaningful reduction
of the taxpayer’s interest in Trenton Trust. Applying the same
analysis used in cases involving section 302(b)(3), this Court
held that the redemptions were integrated steps in a firm and
fixed plan even though there was no binding commitment on the
part of Trenton Trust to acquire the taxpayer’s shares or on the
taxpayer’s part to tender her shares. The Court acknowledged
that each redemption was subject to the financial condition of
the bank and required regulatory approval, but emphasized that
“this was about as firm and fixed a plan as a bank could have
under the circumstances.” Roebling v. Commissioner, supra at 55.
7. Monson v. Commissioner
In Monson v. Commissioner, 79 T.C. 827 (1982), a closely
held corporation owned by the taxpayer and his children redeemed
all of the children’s stock and a portion of the taxpayer’s stock
on July 30, 1976. Immediately following the redemption, the
taxpayer was the corporation’s sole shareholder. On August 2,
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