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 18

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            The parties did not stipulate that the statements in Exhibit 22-V                           
            were true.7  A stipulation that an exhibit is authentic is not a                            
            stipulation to the truth of its contents.  We conclude that the                             
            trust agreement did not require Trust B to distribute interest                              
            and dividend income to Trust C before distributing Ripplestone,                             
            and that respondent did not stipulate otherwise.                                            
                  2.    Amount of Cash Trust B Had To Pay Taxes                                         
                  On June 29, 1990, Trust B had $874,292 in cash or cash                                
            equivalents.  Trust B received interest and dividend income and                             
            paid it to Trust C as follows:                                                              
                                          Income             Income                                     
                              Year        Received           Disbursed                                  
                              1990        $238,276           $216,367                                   
                              1991        55,234             38,518                                     
                              1992        40,085             23,385                                     
                                          $333,595           $278,270                                   
            Trust B paid $278,270 of income from its securities to Trust C.                             
            Trust B would have had $1,152,262 in liquid assets if it had not                            
            distributed that income to Trust C.                                                         
                  Petitioners contend that Trust B only had $220,823 in assets                          
            other than Ripplestone when the estate filed its Federal estate                             




                  7 By selling Ripplestone and then distributing the proceeds                           
            to Trust C, Trust B may have incurred costs that it could have                              
            avoided by transferring Ripplestone to Trust C.  The sale of                                
            Ripplestone may have benefited the heirs because it meant Trust C                           
            did not incur those costs.                                                                  





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