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the subject property to each of Virginia Yegen, Muriel
McNulty and June G. Hall, subject to mortgages and
encumbrances, and shall assign and deliver to Charles
L. Govern, Jr., any and all other assets of the Marital
Trust and shall assign and deliver to Charles L.
Govern, Jr., Virginia Yegen, Muriel McNulty and June G.
Hall in equal shares, any and all other assets of the
Family Trust.
The district court order further provided:
Upon effecting distribution pursuant to this
order, the Trustee will have properly and fully
performed all of the duties, obligations, discretions
and responsibilities placed upon her by the trust
instrument, by the statutes and laws of the State of
Minnesota and by orders of this Court with respect to
the Marital Trust and Family Trust; and she shall
thereupon be, and she hereby is, without further order
of this Court, discharged as Trustee in the above-
entitled matter and released from any further liability
and responsibility with respect to her administration
and distribution of the Marital Trust and Family Trust.
By deed dated February 13, 1992, petitioner as trustee of
the Marital Trust and Family Trust conveyed undivided one-eighth
interests in the Eagan real estate to herself, Muriel McNulty,
and Virginia Yegen, from the Family Trust, and an undivided five-
eighths interest in the Eagan real estate to Charles L. Govern
II, which consisted of an undivided one-half interest in the
Eagan real estate from the Marital Trust and an undivided one-
eighth interest in the Eagan real estate from the Family Trust.
There is a deficiency in estate tax of $12,321 and an
addition to tax under the provisions of section 6651(a) for
$3,080 due from decedent's estate.2 As of June 14, 1995, no
2In Estate of Govern v. Commissisoner, docket No. 17565-93,
(continued...)
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