213683P.pdf   06/02/2023  Thomas Connelly  v.  United States
   U.S. Court of Appeals Case No:  21-3683
   U.S. District Court for the Eastern District of Missouri - St. Louis   
   [PUBLISHED] [Gruender, Author, with Smith, Chief Judge, and Stras, Circuit 
   Judge] 
   Civil case - Federal Tax. Connelly and his brother Michael were the sole 
   shareholders of a corporation and the corporation obtained life insurance 
   on each of them so if one died the corporation could use the insurance 
   proceeds to redeem his shares. When Michael died, the IRS assessed taxes 
   on his estate, which included his stock interest in the corporation. The 
   IRS determined the corporation's fair market value included the life 
   insurance proceeds intended for the stock redemption, and Michael' estate 
   sued for a tax refund. Held, the corporations' value must be determined 
   without regard to the brother's stock-purchase agreement, and the IRS did 
   not err in including the insurance proceeds as part of the corporation's 
   fair market value as the proceeds were a significant asset of the 
   corporation at the time of Michael's death.