The case involves John H. Hendrix and Karolyn M. Hendrix disputing a deficiency in Federal gift tax determined by the IRS for 1999. The dispute centers on the use of formula clauses to value stock in a closely held corporation transferred to family trusts and a charitable foundation. The court ruled in favor of the petitioners, allowing the formula clauses to set the stock's value and permitting the full deduction of the charitable contribution.
documents/EFTA00598147.pdf
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