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Larry, John, Duane, and Rodney Sather (Rodney) are brothers
(the brothers). Larry is married to Kathy, John is married to
Sandra, and Duane is married to Diane. Each of the married
couples has three children.2
The brothers all received their stock in Sathers from their
parents, who started the company. The brothers similarly desired
to pass Sathers to the family's next generation, and, in 1991,
the brothers met with Kaplan to discuss how this could be
accomplished with minimal tax consequences. Kaplan conferred
with Bender-Keller and, after several discussions between one or
more of the brothers and Kaplan, the following occurred. In
1991, Larry created the Larry Trust with his three children as
beneficiaries and Rodney as the trustee, John created the John
Trust with his three children as beneficiaries and Rodney as
Trustee, and Duane created the Duane Trust with his three
children as beneficiaries and John as the Trustee. The brothers
and their respective wives then made the following transfers of
Sathers stock on December 31, 1992.
1992 Reported Gifts
Larry and Kathy
Larry transferred: (1) To each of his three children into
the Larry Trust, 344.3 shares of Sathers stock valued at $75,378
2With respect to any one married couple, we refer to the
children of the other two couples as the nieces and nephews.
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Last modified: May 25, 2011