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judgment of dissolution of marriage on March 12, 1970 (the final
judgment). The 1970 PSA was incorporated into the final judg-
ment. At the time the final judgment was entered, each of the
Edwards children was over 21 years old.
A disagreement between Ann Goss and decedent arose concern-
ing some of the terms of the 1970 PSA. In order to resolve the
disagreement, decedent, Ann Goss, their three children, and the
Company entered into a second property settlement agreement on
January 20, 1984 (the 1984 PSA). On June 6, 1984, a stipulation
for modification of judgment and order thereon was entered by the
California Superior Court (the 1984 court order). The 1984 court
order incorporated the 1984 PSA into the final judgment in place
of paragraph 14 of the 1970 PSA. Paragraph 14 had dealt with the
reciprocal will provisions of petitioner and Ann Goss. In the
1984 court order, decedent was prohibited from modifying, without
prior approval of the court, the Arthur C. Edwards settlement
trust (settlement trust), a revocable living trust that he had
created in 1981. Under the terms of the settlement trust,
decedent was to receive the income from his stock in the Company
and Highland Properties during his life; at his death, Ann Goss
was to receive such income for life; and, at her death, the trust
property was to be distributed to the three children.
On November 6, 1988, the date of decedent's death, the fair
market values of decedent's interests in the Company and Highland
Properties, respectively, were $18,113,960 and $106,184. Pur-
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Last modified: May 25, 2011