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during the trust term to any person other than the grantor or the
grantor’s estate. The two trustees for each respective trust
were petitioner and the daughter for whose benefit the trust was
created.
The following payments were made to petitioner from each of
the GRAT’s:
Date of Form of Number of Value per Amount of
Payment Payment Shares Share Payment
7/9/93 Cash $ 117,381.52
10/4/93 Cash 117,381.52
7/15/94 Stock 1,434,518 $25.1900 36,135,508.42
1/5/94 Cash 117,381.52
4/14/94 Cash 153,498.91
7/3/94 Cash 153,498.91
10/3/94 Cash 92,531.89
6/26/95 Stock 2,142,517 26.1875 56,107,163.94
1/5/95 Cash 92,531.89
4/14/95 Cash 108,861.05
6/26/95 Stock 34,704 26.1875 908,811.00
3,611,739 94,104,550.57
The assets of each GRAT were exhausted upon the final
payment of stock in June of 1995, as all income and principal had
been distributed to petitioner pursuant to the scheduled annuity
payments. Since the aggregate amount of annuity payments called
for by each trust instrument was $108,570,025.58 (49.35 percent x
$100,000,023.56 + 59.22 percent x $100,000,023.56), each GRAT
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