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NOTES 347 Tax Lawyer, Vol. 56, No. 1 NOTE ALLOWING SALES BETWEEN RELATED PARTIES IN CLOSELY HELD CORPORATIONS TO EVIDENCE FAIR MARKET VALUE: A DEPARTURE FROM THE NORM IN MORRISSEY V. COMMISSIONER In Morrissey v. Commissioner,1 the Court of Appeals for the Ninth Circuit reversed the Tax Court and held that in valuing an estate’s interest in a closely held corporation, sales of a minority interest in the corporation’s stock between distant family members were good evidence of fair market value.2 In...

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