The following excerpt is from Coates Trust v. CIR, 480 F.2d 468 (9th Cir. 1973):
Petitioners misconceive the operation and effect of 304. That section was not designed to be so narrowly confined as to relate only to "family" transactions. To the contrary, it was designed to apply to any closely held corporations whether or not the parties were related by blood. The phrase "or more persons" is not superfluous, as petitioners ultimately must contend, but rather indicates an attempt to expand the scope of 304(a)(1) beyond the family relationship to include unrelated persons who act in concert. See Radnitz v. United States, 187 F.Supp. 952 (S.D.N.Y.1960), aff'd per curiam, 294 F.2d 577 (2d Cir. 1961).
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