Connelly v. United States of America, Department of the Treasury, Internal Revenue Service

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION THOMAS A. CONNELLY, IN HIS ) CAPACITY AS EXECUTOR OF THE ) ESTATE OF MICHAEL P. ) CONNELLY, SR., ) ) Plaintiff(s), ) ) v. ) Case No. 4:19-cv-01410-SRC ) THE UNITED STATES OF ) AMERICA, DEPARTMENT OF THE ) TREASURY, INTERNAL REVENUE ) SERVICE, ) ) Defendant(s). ) Memorandum and Order Brothers Michael and Thomas Connelly were the only shareholders in Crown C Supply, Inc., a closely-held family business that sold roofing and siding materials. As is typical in family businesses, the brothers entered into a stock purchase…