Estate of Marguerite S. Millikin, Deceased, Quentin Alexander, Executor, and Severance A. Millikin Trust B, Society National Bank, F.K.A. Ameritrust Company, Trustee - Page 16

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            significantly more Federal estate taxes than the estate reported                            
            on its return and paid.  Petitioners contend that an audit was                              
            nearly certain because the gross estate was large (almost $23                               
            million) and respondent could dispute the fair market value of                              
            Ripplestone.  Petitioners contend that Trust B needed to keep                               
            Ripplestone because it had only $220,822 in assets other than                               
            Ripplestone after the estate filed its estate tax return, and                               
            that $220,822 was not an adequate reserve for its potential tax                             
            liability.                                                                                  
                  Respondent points out that Trust B would have had more than                           
            $220,833 in assets other than Ripplestone if Trust B had not                                
            distributed some of its interest and dividend income to Trust C.                            
            Respondent contends that Trust B was not required to distribute                             
            income to Trust C or to keep Ripplestone as a reserve against                               
            potential tax liability.                                                                    
            D.    Whether It Was Necessary for Trust B to Hold Ripplestone                              
                  After March 16, 1990, and Sell It To Ensure That It Could                             
                  Pay Petitioner's Estate Tax Liability                                                 
                  1.    Whether the Trust Agreement Required Trust B To                                 
                        Distribute Interest and Dividend Income to Trust C                              
                  Under the trust agreement, Trust B's interest and dividend                            
            income, Ripplestone, and all of the other Trust B assets which                              
            decedent did not appoint to Trust A were treated the same.6  The                            

                  6 The trust agreement provided that when decedent dies, the                           
                                                                          (continued...)                





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