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basis. From the time PCAB was incorporated until May 1, 1987,
decedent was a member of the board of directors of PCAB.
On July 28, 1960, all outstanding shares in PCAB were
divided between decedent, who held 567 shares, and Nikita Maggos,
who held 433 shares. On July 29, 1960, decedent and Nikita
Maggos entered into a written “Declaration of Trust”, and
decedent conveyed her 567 PCAB shares and certain real property
located in Illinois into the trust. As a consequence of
decedent’s conveyance of her shares to the trust, PCAB canceled
stock certificates representing decedent’s personal ownership of
the 567 PCAB shares and issued new certificates for those shares
to Nikita Maggos and decedent as cotrustees of the trust.
Under the written terms of the trust, decedent and Nikita
Maggos were cotrustees and had the following rights and
beneficial interests: Decedent had a right to the net income of
the trust during her life and had a limited power of appointment
over the beneficial shares of the remainder interests among the
named residual beneficiaries. The corpus of the trust could be
invaded for the care, comfort, medical attention, support,
maintenance, or education of decedent, at the discretion of the
trustees. Unless the trust was amended, Nikita Maggos, if he
survived decedent, was entitled to the corpus of the trust upon
decedent’s death. As cotrustees, decedent and Nikita Maggos
could jointly, in their sole discretion, revoke or amend the
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