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By July 1, 1991, the other income beneficiaries of the Trust were
petitioner’s mother, Helen True Purcell, hereinafter sometimes
referred to as Purcell, and petitioner’s two siblings. Purcell
and petitioner’s two siblings are hereinafter sometimes
collectively referred to as the other beneficiaries3. Purcell
was entitled to receive 50 percent of the Trust’s income.
Petitioner and her two siblings were each entitled to receive
one-sixth of the Trust’s income. See infra note 3.
Crocker National Bank acted as trustee for the Trust until
May 31, 1986, when Crocker National Bank was acquired by Wells
Fargo Bank. Wells Fargo Bank, hereinafter sometimes referred to
as the Trustee, has acted as the Trust’s Trustee since May 31,
1986.
Petitioner’s husband, Joseph DiLeonardo, hereinafter
sometimes referred to as DiLeonardo, is licensed by California as
both an attorney and a real estate broker.
The Third Account and the Objections
On July 5, 1991, the Trustee filed with the Superior Court
of the State of California for the County of Los Angeles
(hereinafter sometimes referred to as the California Court), its
3 There also was a lifetime annuitant, who was entitled to
receive $100 per month. This annuitant did not play a role in
the proceedings described infra; her interest was sufficiently
insignificant so that we join the parties in ignoring it for
purposes of analyzing the parties’ dispute in the instant case.
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