Estate of Ida Abraham, Deceased, Donna M. Cawley, and Diana A. Slater, Administratrixes - Page 7

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               8.  Mr. Richard Abraham, Ms. Cawley, and Ms. Slater shall              
          share “pro rata” all gift and estate tax liabilities of decedent.           
               Decedent’s estate plan evolved in numerous steps and                   
          employed the use of many entities:6                                         
               (1) Three separate real estate trusts were formed to hold              
          the real property interests:7  (a) The DAC Tyngsboro Real Estate            
          Trust was formed on October 1, 1995, naming Ms. Cawley as                   
          trustee, and on October 6, 1995, that trust was deeded a one-               
          half, undivided interest in the Tyngsboro property; (b) the RMA             
          Walpole Real Estate Trust was formed on October 1, 1995, naming             
          Mr. Richard Abraham as trustee, and on that day that trust was              
          deeded the Walpole property;8 and (c) the DAS Real Estate Trust             
          was formed on October 1, 1995, naming Ms. Slater as trustee, and            
          on October 6, 1995, that trust was deeded a one-half, undivided             
          interest in the Tyngsboro property.9  On the date that the                  
          Tyngsboro property was transferred to the DAS and the DAC real              


               6Decedent’s estate plan, which benefited Mr. Richard                   
          Abraham, differed slightly from those of Ms. Cawley’s and Ms.               
          Slater’s, and where relevant, we shall indicate any substantive             
          differences.  However, most of the terms in the documents which             
          created the entities/structures herein discussed are                        
          substantially similar.                                                      
               7The parties stipulated that certain real properties were              
          “placed” in the FLPs.                                                       
               8As discussed infra, the Smithfield property was deeded to             
          an FLP.                                                                     
               9Decedent, through her coguardians, deeded the properties to           
          the real estate trusts.                                                     




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