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property was to be distributed equally to certain tax-exempt
charitable organizations. On the valuation date, the QTIP trust
held 2,460,580 shares of FOH stock, which then constituted
27.8671 percent of the issued and outstanding stock of FOH.
After Mr. Mellinger's death, decedent removed her share of
the community property, 2,460,580 common shares of FOH, from the
family trust and contributed it to the revocable trust that she
established to be known as the Harriett R. Mellinger Revocable
Trust (the Harriett trust). The stock that was held by the
Harriett trust also constituted 27.8671 percent of the issued and
outstanding stock of FOH. Hunter and Wells Fargo Bank were
designated as cotrustees. Under the terms of the Harriett trust,
upon the death of decedent, the cotrustees were directed to make
certain specific gifts and to sell decedent's personal residence
and distribute the sales proceeds to decedent's children. The
balance of the Harriett trust was to be held for distribution
with certain annual and periodic cash amounts to be made to the
children and specified grandchildren. Upon the death of such
children and grandchildren, the remaining trust estate was to be
distributed equally to certain charitable organizations. At the
valuation date, decedent also owned 50 shares of FOH outright.
Hunter and Wells Fargo Bank (coexecutors) filed a United
States Estate (and Generation-Skipping Transfer) Tax Return, Form
706, for decedent's estate on January 18, 1994. On the return,
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