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surviving corporation in the merger. The value of CamVic stock
used to compute the exchange ratio for the merger was $14,192.45
per share.
On January 5, 1973, decedent created the Cameron W. Bommer
Trust (CWB Trust),6 to which he transferred his entire interest
in CamVic. Although revocable during decedent's lifetime, the
trust was to become irrevocable upon his death. Decedent
reserved the right to vote his CamVic stock as well as to
preclude its sale or transfer during his lifetime. Kenneth
Hughes was the sole trustee of the CWB Trust from its inception
through April 27, 1981, when he was replaced by Ronald. Ronald
remained sole trustee through the date of decedent's death.7
4(...continued)
driving range. A par three, nine-hole golf course, a pro shop,
and a snack bar were added later. CamVic continued to operate
the facilities until the end of 1977.
5Bommer Builders, Inc., was incorporated on Dec. 22, 1953.
Decedent and Victor Fay owned 105 and 70 shares, respectively.
These shares were issued in consideration for the transfer of all
assets and the assumption of all liabilities of Bommer Builders
partnership. The sale documents listed the net value of the
assets of Bommer Builders partnership at the time of the transfer
at $17,500.
6The trust was amended or revised on Apr. 27, 1981, Aug. 27,
1982, July 22, 1986, Jan. 27, 1987, Feb. 28, 1990, and June 5,
1990. The documents clearly indicate on their face that they are
amendments, and they also state the dates upon which they were
executed.
7Subsequent to decedent's death and pursuant to the terms of
the CWB Trust, three new trusts were created: The Credit Shelter
Trust, the Exempt QTIP Trust, and the QTIP Trust.
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