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Each of the 25 Bea Ritch Trusts had an employer
identification number and filed tax returns. There is no single
or individual trust or partnership named "Bea Ritch". Bea Ritch
Trusts or BRT is a reference name used to refer collectively to
the 25 trusts created by the trust agreement.
Kanter was originally a beneficiary of each of the 25 BRT
trusts. He partially renounced and disclaimed his interest in
BRT on January 6, 1971, and renounced the remainder of his
beneficial interest in BRT on January 20, 1977. He further
signed a renunciation and disclaimer of his beneficial interests
in BRT on September 15, 1978.
The original beneficiaries of BRT also included Kanter's
wife, Naomi, and their children. The original beneficiaries were
all individuals. Kanter's wife was originally a beneficiary in
nine of the trusts.
Article III of the trust agreement establishing Bea Ritch
Trusts, Beatrice K. Ritch, Grantor, provides in pertinent part as
follows:
3.1 Income and Principal. The Trustee is hereby
authorized to distribute all or as much of the net
income or principal or both of a separate trust to the
beneficiary or to any one or more of the beneficiaries
of such trust as the Trustee deems to be in the best
interests of said beneficiary or beneficiaries.
3.2 Limited Powers of Appointment. The Grantor's son
may, during his lifetime and upon his death, appoint
all or any part of the trust estate of each separate
trust of which he shall be a beneficiary to or for the
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