Estate of Emerson Winkler, Deceased, Thomas Winkler and Darrell S. Winkler, Co-Executors, et al. - Page 3

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             claimed for estate tax purposes by the amount of                          
             Mr. Winkler's interest in a family partnership on the                     
             ground that Mrs. Winkler's disclaimer of that interest was                
             invalid.                                                                  
                                   FINDINGS OF FACT                                    
                  Some of the facts have been stipulated and are so                    
             found.  The stipulation of facts and attached exhibits are                
             incorporated herein by this reference.  At the time the                   
             instant petitions were filed, Mrs. Elizabeth Winkler and                  
             the co-executors of the Estate of Emerson Winkler were                    
             residents of the State of Illinois, and the Estate of                     
             Emerson Winkler was being administered in the State of                    
             Illinois.                                                                 
                  Mr. and Mrs. Winkler had been married for over 50                    
             years prior to Mr. Winkler's death on March 11, 1992.  Both               
             Mr. and Mrs. Winkler graduated from high school but neither               
             received any other formal education.  When he died,                       
             Mr. Winkler was a retired farmer, and the couple was living               
             on the family farm in Armington, Illinois.                                
                  Mr. and Mrs. Winkler had five children during their                  
             marriage:  Ms. Charlotte Sutter, Ms. Susan Litwiller,                     
             Ms. Sharon Swartzendruber, Mr. Thomas Winkler, and                        
             Mr. Darrell (Steve) Winkler.  The Winklers were a very                    
             close family.  All of the children but Steve lived within                 





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