Estate of Irene H. Govern, Deceased, Revocable Trust of Charles S. Govern, Sr., Transferee, June G. Hall, Trustee and Transferee, June G. Hall, Transferee of Transferee, Muriel McNulty, Transferee o - Page 6

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          trustee in possession of the Marital Trust property that was                
          includable in decedent's gross estate.  The affidavit further               
          states that decedent pursuant to her last will has exercised her            
          general testamentary power of appointment over the Marital Trust            
          by appointing all of the trust assets to Charles L. Govern II.              
          Petitioner acknowledged that the assets of the Marital Trust,               
          consisting of the Eagan real estate, had not yet been distributed           
          to Charles L. Govern and that she continued to hold legal title             
          thereto in her capacity as trustee.  Petitioner said that she               
          expected that on or about May 30, 1990, she would be directed by            
          the District Court of Dakota County, Minnesota, to issue a deed             
          to Charles L. Govern, Jr., for an undivided one-half interest in            
          the Eagan real estate.                                                      
               The Federal estate tax return filed by petitioner contained            
          certain appraisal information relating to the Eagan real estate             
          and identified decedent's power of appointment over the Marital             
          Trust but did not ascribe a value to the real estate and                    
          expressly disclaimed knowledge of other assets held by decedent's           
          estate.                                                                     
               On July 8, 1991, the District Court, County of Dakota, State           
          of Minnesota issued an order requiring petitioner, as trustee of            
          the Marital Trust and Family Trust, to:                                     
               execute and deliver to Charles L. Govern, Jr. [sic], a                 
               deed for an undivided five-eighths interest in the                     
               subject property [the Eagan real estate], subject to                   
               mortgages and encumbrances, and shall execute and                      
               deliver a deed for an undivided one-eighth interest in                 




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