Audrey J. Walton - Page 3

                                        - 3 -                                         
          of 3,611,739 shares of the above Wal-Mart stock.  The fair market           
          value of the Wal-Mart stock on that date was $27.6875 per share,            
          and the consequent initial fair market value of each trust was              
               According to the provisions of each GRAT, petitioner was to            
          receive an annuity amount equal to 49.35 percent of the initial             
          trust value for the first 12-month period of the trust term and             
          59.22 percent of such initial value for the second 12-month                 
          period of the trust term.  In the event that petitioner’s death             
          intervened, the annuity amounts were to be paid to her estate.              
          The sums were payable on December 31 of each taxable year but               
          could be paid up through the date by which the Federal income tax           
          return for the trust was required to be filed.  The payments were           
          to be made from income and, to the extent income was not                    
          sufficient, from principal.  Any excess income was to be added to           
               Upon completion of the 2-year trust term, the remaining                
          balance was to be distributed to the designated remainder                   
          beneficiary.  Petitioner’s daughter Ann Walton Kroenke was the              
          beneficiary so named under one trust instrument; petitioner’s               
          daughter Nancy Walton Laurie was named in the other.                        
               Each trust was irrevocable, prohibited additional                      
          contributions, specified that the grantor’s interest was not                
          subject to commutation, and mandated that no payment be made                

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011