- 18 - 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.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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