This case involves a closely held New York corporation, Patricia Holding Corp., which was established in 1936 by Max Silverstein and Frank Hillman, each of whom had 50% of its shares. The sole business of Patricia has been, and continues to be, the ownership and operation of two parcels of real estate, a commercial-residential building in The Bronx and a store in Brooklyn. Following the death of the two principals, the stock passed by inheritance to their children and grandchildren...
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