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On January 29, 1990, Mr. Stevens executed a First Amendment
to the Trust Agreement, modifying the estate tax apportionment
provisions of the Trust. (The Trust Agreement and the First
Amendment are collectively hereinafter referred to as "the Trust
documents".)
On December 3, 1991, Mr. Stevens died. Under the terms of
the Trust Agreement, the Trust became irrevocable upon his death,
and petitioner, who was Mr. Stevens’ second wife, became the
Successor Trustee. Petitioner was also a beneficiary of the
Trust.
The Trust Agreement instructed petitioner, the Successor
Trustee, to distribute $100,000 and certain other property to Mr.
Stevens’ son from his first marriage, Matron Garland Stevens
(Garland). The Trust Agreement further instructed petitioner to
distribute certain real property to Sedra Jean Farrow (Sedra),
the daughter of Mr. Stevens and petitioner. These distributions
were made in accordance with the Trust documents.
After the distributions were made to Garland and Sedra, the
balance of the Trust property was distributed by petitioner, as
Successor Trustee, to herself as the Trustee of a Marital Trust
created by the Trust Agreement for her benefit. As beneficiary
of the Marital Trust, petitioner is entitled to receive the net
income from the Marital Trust as well as discretionary
distributions of principal. In addition, petitioner has been
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Last modified: May 25, 2011