Citizens Bank & Trust Company v. Commissioner of Internal Revenue

POSNER, Circuit Judge.

This appeal from the Tax Court presents a difficult question in the administration of the federal gift and estate taxes. The essential facts are simple, however. After a merger of several commonly owned corporations, four siblings — John and William Curran, Cecilia Simon, and Judy Pokomy— each owned 25 percent of both the voting and nonvoting common stock of the Curran Contracting Company. The company is a substantial corporation involved in manufacturing, distribution, and real estate. It is managed by John and William Curran. The four siblings wanted to maintain family…