This article looks into the situation in which Section 303 is beign planned for use in a corporation that is over-capitalized. "Under its provisions the stockholder of a closely held corporation can look to the corporation to purchase sufficient shares of his stock in order to permit his executor to pay estate and inheritance taxes, executor's and attorney's fees and funeral expenses. The asset, his stock in the closed corporation, which has chiefly caused this stockholder's estate problem, will be used to solve it."
Mel J. Massey Jr., Section 303 Stock Repurchase vs. Accumulated Earnings Tax, 17 Clev.-Marshall L. Rev. 175 (1968)