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A. Petitioners
Decedent lived in Ohio when she died on June 18, 1989. She
was the surviving spouse of Severance A. Millikin, who died in
1985. On November 19, 1987, decedent executed her will, in which
she left the residue of her estate to her inter vivos trust.
Quentin Alexander (Alexander) is executor of decedent's estate
and Society National Bank, formerly Ameritrust Co. (Ameritrust),
is trustee of the Millikin trusts.
B. The Millikin Trusts
In 1976, decedent's husband named Ameritrust trustee for
three trusts which he established.
1. Trust A
Decedent's husband established a charitable trust known
as the Severance A. and Marguerite S. Millikin Endowment Fund
Trust A (Trust A).
2. Trust B
Decedent's husband established the Severance A. Millikin
Trust B (Trust B) as a marital deduction trust. Under his will,
Ripplestone was transferred to Trust B on May 7, 1986, to be held
by Trust B for decedent's benefit as long as she wanted to live
there.
Decedent had a general power of appointment for all Trust B
property, including Ripplestone. If decedent did not fully
exercise her power of appointment, any unappointed Trust B
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