On July 12, 1990, petitioner Clinton Glenn purchased from respondent M. Neil Redford all shares of Bell Redford Glenn, Inc. (BRG), a subchapter "S" corporation. Under the terms of the stock purchase agreement, Redford resigned as president and secretary of BRG and was elected chairman of the corporation's board of directors; Glenn became the president, chief executive, and chief administrative officer of the corporation, with sole authority for its daily operations. Also...
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