The following excerpt is from Estate of Gloeckner v. C.I.R., 152 F.3d 208 (2nd Cir. 1998):
Moreover, it is appropriate when analyzing the relationship between the decedent and the beneficiaries of a restrictive agreement to look at not only the relationship itself, but also the circumstances surrounding the agreement. See Slocum v. United States, 256 F.Supp. 753, 755 (S.D.N.Y.1966) (holding that the family relationship among the shareholders, combined with the poor health of one of those family members at the time the restrictive shareholder agreement
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