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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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