One of the problems in determining whether this test is met is that most purchase and sale agreements are negotiated to deal with unique facts and circumstances and are not public documents. It is apparent from the terms of the agreement that both policies were taken over by the survivor. The purpose of the conclusion of these policies was to allow the survivor, after the death of the deceased, to acquire the deceased`s shares in both companies. The premiums for these policies were paid or paid by the survivor, in other words, they were not paid or borne by the deceased. Possible treatment of the sale as a dividend. The general rule of imposing a withdrawal of shares is very different from the rules applicable to the treatment of a sale through a cross purchase contract. .