Estate of Pearl I. Amlie, Deceased, Rodney B. Amlie, Executor - Page 32

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          787 (Iowa 1901) (actions taken on ward's behalf by conservator              
          under the direction of the probate court are binding on ward,               
          absent fraud).23                                                            
               In sum, we conclude the 1995 FSA satisfies the pre-section-            
          2703 requirements that it set a fixed and determinable price, and           
          that it be legally binding during life and at death.                        
          Section 2703 Requirements                                                   
               Respondent further argues that, even if it is conceded that            
          the 1995 FSA created enforceable buy/sell options establishing a            
          price that bound decedent, the 1995 FSA is nonetheless                      
          disregarded for Federal estate tax purposes under section                   
          2703(a), because it fails to satisfy the requirements of section            
          2703(b) for exempting a restrictive agreement from the                      
          "disregard" rule of section 2703(a).  The estate contends that              
          all requirements of section 2703(b) have been satisfied, and we             
          agree.                                                                      
               Section 2703(b) provides that a restrictive option or                  
          agreement will not be disregarded under section 2703(a) if it               
          meets each of the following requirements:                                   
               SEC. 2703(b). Exceptions.-- * * *                                      


               23 Respondent also argues that decedent was not bound by the           
          1995 FSA because she received no consideration for entering it.             
          We think the consideration received by decedent is patent;                  
          namely, a fixed price for the FABG stock that was otherwise                 
          contingent upon further negotiations and/or litigation with FABG.           






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