 | United States. Congress. Senate. Committee on Small Business - 1990 - 272 lapas
...device to pass the decedent's shares to the natural objects of his bounty for less than an adequate and full consideration in money or money's worth. The...produced a $0 value. A common situation is a parent selling the business to an active child at a fixed formula price derived in arms-length negotiations.... | |
 | United States. Congress. Senate. Committee on Small Business - 1990 - 278 lapas
...device to pass the decedent's shares to the natural objects of his bounty for less than an adequate and full consideration in money or money's worth. The...have an estate planning motive rather than a business •otive. For example, the courts have backed Treasury when it ignored an option formula which produced... | |
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... disregarded in determining the value of the securities unless it is determined under the circumstances of the particular case that the agreement represents a bona fide business arrangement and not a device to pass the decedent's shares to the natural... 