Estate of Catherine E. Dowell, Deceased, Patricia Low, Executrix - Page 17

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          to petitioner, is an interest in the stock that qualifies for the           
          marital deduction.                                                          
               Petitioner also argues that Patricia Low paid no attention             
          to the agency's corporate tax returns and her individual tax                
          returns and that she did not notice that the returns treated her            
          as the sole shareholder of the agency.  Petitioner further argues           
          that nothing Patricia Low did after her mother's death could                
          possibly have a bearing on decedent's intentions when drafting              
          her will and codicil.                                                       
               In the alterative, petitioner argues that the will merely              
          gave Patricia Low an option to buy the stock.  Patricia Low                 
          testified that her mother told her she would have an opportunity            
          to purchase the agency stock upon her mother's death, and                   
          petitioner argues that decedent's attorney, Jan Seigel, supported           
          this interpretation.  Respondent counters by pointing out that              
          the testimony is self-serving, uncorroborated, and incredible               
          since the stock purchase agreement already gave Patricia Low an             
          option to purchase the agency stock upon her mother's death, and            
          her actions after her mother's death call her veracity into                 
          question.                                                                   
               Petitioner argues that the New Jersey doctrine of probable             
          intent controls the interpretation of decedent's will, not                  
          general rules of will construction.  According to petitioner,               
          decedent would not have wanted her daughter to inherit any stock            
          if she did not fully and completely comply with her wishes, as              




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