EXHIBIT 99.1Stock Disposition Agreement • September 26th, 2001 • Sterling Financial Corp /Pa/ • National commercial banks • Pennsylvania
Internal Revenue Service, Treasury § 25.2704–1Stock Disposition Agreement • January 23rd, 2020
terms of the lease were not comparable to leases of similar property entered into among unrelated parties. The lease is a re- striction on the use of the property that is disregarded in valuing the property for Fed- eral estate tax purposes.
disregarded in valuing the property for Fed- eral estate tax purposes.Stock Disposition Agreement • October 17th, 2014
Example 2. T and T’s child, C, each own 50 percent of the outstanding stock of X cor- poration. T and C enter into an agreement in 1987 providing for the disposition of stock held by the first to die at the time of death. The agreement also provides certain restric- tions with respect to lifetime transfers. In 1992, as permitted (but not required) under the agreement, T transfers one-half of T’s stock to T’s spouse, S. S becomes a party to the agreement between T and C by reason of the transfer. The transfer is the addition of a family member to the right or restriction. However, it is not a substantial modification of the right or restriction because the added family member would be assigned to a gen- eration under section 2651 of the Internal Revenue Code no lower than the generation occupied by C.
