Robert Joseph Looby and M. Patricia Looby - Page 3

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          bequests of cash on hand in two savings accounts to petitioner              
          and her sister, respectively, and monetary bequests of $25,000              
          each to two family members3 and a friend.  The "rest, residue and           
          remainder" of the estate was to be divided between petitioner               
          (25%), her sister (25%), and a trust (50%) to be created by the             
          executors for the benefit of the children of petitioner and her             
          sister.                                                                     
               In her will, the decedent named her brother-in-law,                    
          William F. Hyland (Hyland), and Patrick J. Scinto (Scinto) as               
          co-executors of her estate.  The co-executors were granted broad            
          power to administer and distribute the estate, including the                
          power to sell, lease, invest and reinvest all or part of the                
          decedent's estate, "real, personal and mixed".                              
               The estate                                                             
               Along with the previously mentioned savings accounts, and              
          miscellaneous personalty, the estate included 4 parcels of real             
          property that were disposed of as follows:  (1) The decedent's              
          personal residence in Bronxville, New York, was sold by the                 
          executors on February 23, 1983; (2) a vacant lot in Yonkers, New            
          York, was sold by the executors on May 18, 1983; (3) commercial             
          property in Mobile, Alabama, was sold by the executors in May of            
          1985; and (4) commercial property in Chicago, Illinois, was sold            
          by the executors on October 31, 1986.                                       

          3Mark Hyland and Sharon Hyland, adult children of co-                       
          executor William F. Hyland.                                                 




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