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Hartman v. United States

Mrs. Hartmann made gifts of shares of a close-held corporation to her son and grandchildren.

After the gifts, no shareholder owned a majority of the shares of the corporation The Internal Revenue Service contended that the shares owned by the individual owning the greatest number of shares – though not a majority of the shares – should, by virtue of such “persuasive position” be valued as if such shares represented a majority position.  No. . 97-1335 (D. Ill. 1997).

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