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following family trusts were formed: The DAS Family Trust, the
DAC Family Trust, and the RMA Family Trust. Mr. Goldman was
named the trustee of the DAS and DAC family trusts, and Mr. Rubin
was initially named the trustee of the RMA family trust.12 Under
the agreement for each family trust, the trustee was granted the
following power:
During Ida’s lifetime the Trustees in their discretion shall
pay the net income and principal of the trust property to
Ida during her lifetime for her benefit and may also make
payments to any one or more of her * * * [children: Mr.
Richard Abraham, Ms. Cawley, and Ms. Slater and their] issue
and the spouse of * * * [children] to utilize gift tax
exclusions.
Upon her death, the trustee was to transfer the balance of the
principal of the trust property to separate “family trusts” for
the benefit of decedent’s children, Mr. Richard Abraham, Ms.
Cawley, and Ms. Slater, or in accordance with each child’s
general power of appointment.
Initially, with respect to the DAS and DAC FLPs, decedent
held a 98-percent limited partnership interest, the corporate
general partners, DAS, Inc., and DAC, Inc., each held a 1-percent
interest, and Ms. Cawley and Ms. Slater each held a 1-percent
interest.13 Similarly, decedent initially held a 99-percent
12Mr. Richard Abraham and his wife, Jacqueline, became
cotrustees of the RMA Family Trust on Jan. 15, 1996.
13Except for a letter discussed infra, there is no
indication in the record that Ms. Cawley and Ms. Slater paid any
consideration for 1-percent interests in the FLPs. See infra
(continued...)
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