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CITIZENS BANK & TRUST CO. v. C.I.R.

No. 87-1536.

839 F.2d 1249 (1988)

CITIZENS BANK & TRUST COMPANY, et al., Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided February 16, 1988.

Attorney(s) appearing for the Case

James A. Clark, Schiff, Hardin & Waite, Chicago, Ill., for petitioners-appellants.

Mary Frances Clark, Asst. Atty. Gen., U.S. Dept. of Justice, Washington, D.C., for respondent-appellee.

Before POSNER and FLAUM, Circuit Judges, and ESCHBACH, Senior Circuit Judge.

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 Pokorny — each owned 25 percent of both the voting and nonvoting common stock of the Curran Contracting Company...

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