CA10(12.02.04)

True v. Commissioner, Nos. 02-9010, 02-9011, 02-9012, affirms the Tax Court's decision.

Mr. True was an entrepreneur whose business strategy requires that all of his associates and parters execute “buy-sell” agreements which treated their “Failure to work in the business, any attempt to transfer an interest in the business, death, and disability [as a notification that] the other owners of his or her intent to withdraw from ownership.” The agreements included a formula to unwind their interests that was based on the tax bluebook value. The Tax Court held, and the Court of Appeals Affirmed that for purposes of valuing the estate, the blue book values used in the buy-sell agreements were not dispositive.