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From time to time, the decedent discussed estate tax
matters with his friends and acquaintances. On those
occasions, he urged them to plan to avoid estate taxes.
He did not disclose any specific provisions of his will or
his wife's will, except to say that his sons would be co-
trustees and that his wife, children, and grandchildren
would not have to worry about the estate. The decedent
stated that he trusted Mr. Richard Rapp to handle financial
matters and to look after Mrs. Rapp in the event of his
death. The decedent also told his friends that he caused
his will to be updated to account for changes in the law,
and he advised them to do the same. The decedent told
Mr. Bruce Bell, an employee of Wells Fargo Bank who
supervised the decedent's and MTSS's loan accounts with the
bank, that there would be minimal estate taxes and minimal
liquidity problems at the time of his death.
The decedent also discussed the estate tax marital
deduction with his accountant, Mr. Lippert. Sometime
between 1984 and 1986, the decedent showed Mr. Lippert an
article about the marital deduction permitted for Federal
estate tax purposes. The decedent told Mr. Lippert that he
was "moving forward in that area." On other occasions, the
decedent told Mr. Lippert that his estate tax matters were
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