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Benefit Plans which Invest In Stock of a Closely Held
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aapun aaq3 aaqa acquisition adequate consideration apply aq3 uo cash flow closely held corporations Code common stock contributions control premium conversion premium convertible preferred stock Corporate Partners deduction determination directors distribution dividends election employer securities employer stock ERISA ESOP loan ESOP note ESOP participants Esquire estate tax excise tax exempt fair market value FERSA independent appraiser interest investment manager investors IRC Section issues leveraged ESOP limited named fiduciary non-leveraged nonrecognition transaction nonrecognition treatment outstanding parties pass-through plaintiffs plan assets plan fiduciary Polaroid Corporation prohibited transaction proposed regulation Proposed section proxy purchase pursuant put option pxno qualified plan qualified replacement property qualified securities readily tradable recognized market requirements rules self-tender selling shareholder Shamrock Holdings stock bonus plan stockholders takeover taxpayer tender offer tion Treas trustee uaxd Unocal utxd valuation