Estate of Marguerite S. Millikin, Deceased, Quentin Alexander, Executor, and Severance A. Millikin Trust B, Society National Bank, F.K.A. Ameritrust Company, Trustee - Page 5

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            property was to be transferred to a residuary trust known as the                            
            Severance A. Millikin Trust C (Trust C) when decedent died.                                 
            Trust B and/or Trust C were to pay all expenses necessary to                                
            maintain Ripplestone during decedent's life.  The trust document                            
            required the trustee to distribute all Trust B property according                           
            to decedent's will.                                                                         
                  Decedent's will required Trust B to pay all Federal and                               
            State death taxes attributable to the inclusion of Trust B in her                           
            gross estate.                                                                               
                  3.    Trust C                                                                         
                  Decedent's husband established Trust C to benefit some of                             
            his and decedent's relatives.  When decedent died, Trust C was to                           
            be divided into three equal shares to be held in trust for the                              
            benefit of the issue of three named relatives of decedent's                                 
            husband.  Each of the three shares was to be held for the issue                             
            of the three relatives per stirpes.  Trust C had 28                                         
            beneficiaries.                                                                              
            C.    Ripplestone                                                                           
                  Ripplestone had about 150 acres on which were buildings                               
            including a 7,900-square-foot stone main house, a detached three-                           
            car garage with apartments, a stone pool house, a gate house and                            
            stable, a chauffeur's cottage, and an old farmhouse with a barn.                            
            The main house had a large living room used as a gallery to                                 
            display an extensive art collection.                                                        





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