Before the value of the shares was determined, the decedent’s estate liquidated the corporation.  After the value of the shares was determined, the decedent’s estate, in relying upon an informal refund request, sued for a refund of the excess of the income taxes paid without regard to the basis increased over the over the income taxes payable by reason of the basis increase.  874 F.2d 1165 (7th Cir. 1989).