Sharon Purcell DiLeonardo - Page 11




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               of the Trust; that each and all of her Objections to                   
               the Third Account were intended by her to be punishment                
               and vindictive; that Sharon DiLeonardo’s bad faith was                 
               compounded by her stonewalling on discovery; and that                  
               she willfully suppressed material evidence.                            
               The California Court ordered petitioner to pay the                     
          litigation costs, plus interest, of the other beneficiaries, the            
          Trustee, and the guardian ad litem.  Petitioner’s obligations               
          under this order are hereinafter sometimes referred to as the               
          Payments.  The California Court further ordered that the Payments           
          be paid out of petitioner’s portion of distributions from the               
          Trust.  The amounts the Trustee was directed by the California              
          Court to pay, and the payees, are summarized in Table 1.                    
                                       Table 1                                        
                         Payee                         Amount                         
                    Other beneficiaries                $203,474.91                    
                    Trustee and guardian ad litem       147,040.75                    
                    Total                               350,515.66                    
               The California Court’s order was affirmed by the California            
          Court of Appeal for the Second District.  Estate of Ivey v.                 
          DiLeonardo, 28 Cal. Rptr. 2d 16 (Ct. App. 1994).                            
          Tax returns                                                                 
               Table 2 shows selected items from petitioner’s tax returns.            
                                       Table 2                                        
                                        1993                   1994                   
               Income from the Trust         $49,546.00    $113,478.00                
               Adjusted gross income         50,571.93     120,540.70                 
               Litigation cost deduction    53,000.00     159,718.00                  
               (before 2-percent floor)                                               




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