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were made. All Rule references are to the Tax Court Rules of
Practice and Procedure.
FINDINGS OF FACT
Some facts have been stipulated and are so found. The
stipulation of facts, with accompanying exhibits, is incorporated
herein by this reference.
Introduction
At the time the petitions herein were filed, petitioners
Lloyd Peterson and Kyle C. Brooks both resided in Hamilton
County, Ohio. Decedent died testate on October 27, 1992.
Decedent's Wills
Between January 17, 1951, and June 4, 1991, decedent
executed six wills and six codicils. By his will dated June 15,
1981 (the 1981 will), decedent bequeathed the residue of his
estate in trust for the support and care of his invalid adult
daughter. With respect to the funds to be placed in trust, the
1981 will provided: “Out of the net income, also, a compensation
shall be paid to Rose A. Bell, for such care, attention and
services as she may be able to render to my said daughter". The
1981 will also contained a devise and specific bequests to Bell,
including decedent’s residence (with the provision that
decedent’s daughter be allowed to live there until an alternative
residence was made available to her), his personal property,
$100,000, and three grave sites. By the 1981 will, decedent also
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