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 6

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                  Ripplestone had six underground fuel storage tanks which had                          
            leaked and contaminated soil near the farmhouse and soil and                                
            groundwater near the garage apartments.  Developers wanted, but                             
            were unable, to subdivide Ripplestone into lots that were smaller                           
            than five acres.  There was substantial local opposition to                                 
            subdividing Ripplestone.  Petitioners did not know about the                                
            environmental or zoning problems until after the estate filed the                           
            estate tax return.                                                                          
            D.    Trust B's Assets When Decedent Died                                                   
                  Ameritrust, as trustee for Trust B, held title in trust to                            
            Ripplestone.  Trust B held assets which had a fair market value                             
            of $11,433,458.03 when decedent died on June 18, 1989, including                            
            Ripplestone with a fair market value of $2.4 million and stock,                             
            Treasury Bills, and an investment trust with fair market value of                           
            $9,033,458.03.  When decedent died, Trust B had accrued                                     
            liabilities of $41,935.34, which were for trustee's fees.                                   
                  Decedent's gross estate included the property held by Trust                           
            B because it was subject to her general power of appointment.                               
            Sec. 2041(a).  However, the property held by Trust B was not a                              
            probate asset and was not subject to claims against decedent's                              
            estate.                                                                                     










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