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these purported claims is valid, the value of decedent's
estate will rise and thus also the estate tax liability of
her estate. To determine the validity of these claims, we
must examine Mr. de St. Aubin's will, his estate, and the
trusts created under the will.
FINDINGS OF FACT
Honore V. de St. Aubin (decedent) died December 27,
1983. Sixteen years earlier, on November 18, 1967, her
husband, Ovide de St. Aubin, Jr. (Mr. de St. Aubin), died,
survived by decedent and their four adult children, Ovide
E. de St. Aubin (the younger Mr. de St. Aubin), Honore
O'Brien, Corinne Shaw, and Celeste Schettig.
Decedent's husband provided for her in his will.
Under Article Fourth of his will, he devised to Honore his
house and land located in New Rochelle, New York, which had
an estate tax value of $73,500. Under Article Fifth of his
will, he bequeathed to Honore all of his personal property,
including a yacht and two automobiles. The personal
property had an aggregate estate tax value of $145,749.
Decedent's husband had also designated her as beneficiary
of insurance policies on his life, with an aggregate value
of more than $175,000. In addition, decedent owned
insurance on her husband's life, which paid her a death
benefit of more than $100,000.
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