- 3 -
Background
Petitioners resided in Bloomington, Indiana, at the time
their petition was filed with the Court.
The following is a summary of the relevant facts. They are
stated solely for the purpose of deciding the pending cross-
motions for partial summary judgment, and they are not findings
of fact for this case. See Fed. R. Civ. P. 52(a); Rule 1(a).
The Creation of the Trusts
On June 7, 1993, petitioner William A. Cook (Mr. Cook)
created the William A. Cook 1993 grantor retained annuity trust
and transferred 12,600 shares of Class A common stock of Cook
Group, Inc., to such trust. On the same day, petitioner Gayle T.
Cook (Mrs. Cook) created the Gayle T. Cook 1993 grantor retained
annuity trust and transferred 12,600 shares of Class A common
stock of Cook Group, Inc., to such trust.
On August 30, 1995, Mr. Cook created the William A. Cook
1995 grantor retained annuity trust and transferred 14,360 shares
of Class A common stock of Cook Group, Inc., effective August 31,
1995, to such trust. On the same day, Mrs. Cook created the
Gayle T. Cook 1995 grantor retained annuity trust and transferred
11,300 shares of Class A common stock of Cook Group, Inc.,
effective August 31, 1995, to such trust.
Petitioners were named as cotrustees for each of the GRAT’s.
Each GRAT also provides that it is intended to be a grantor
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011