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BuySell Agreements as Asset Freezing Devices
Recapitalizations and Related Asset Value Capping
Valuation of Closely Held Securities for Estate
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$100 par value accompanying text allocation amount apply asset freeze basis business purpose buy-sell agreement Byrum capital account capital interest cash flow charity closely held Commissioner common stock contributed property corporation corporation's court death decedent decedent's deduction distribution dividend donor entity equity estate freeze estate tax excess exchange fair market value family members family partnership frozen interest frozen partner frozen stakeholder future appreciation gross estate guaranteed payment holder holding company income tax Internal Revenue Service limited partner limited partnership interest liquidation preference loan Louis County McKee Nelson & Whitmire nonvoting ownership partnership agreement partnership assets partnership freeze partnership income preferred stock premium Private Letter Ruling profits recapitalization receive regulations retained rule Service shareholders shares Stock voting supra and accompanying supra note 20 tax planner tax purposes taxable gifts taxpayer tion transfer tax Treas trust unfrozen valuation voting control voting rights