Fennel Trust - Page 6




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          trust document for another trust known as Tarragon Trust.7                  
               Article Five “Power of Trustees”, section 5.5 of the Fennel            
          trust instrument states as follows:                                         
                    NOTWITHSTANDING any other provision in this Trust                 
               instrument, no power shall be exercised, nor any action                
               taken, by the Trustees except upon the unanimous                       
               consent of all Trustees having authority as                            
               supplemented by the minutes and resolutions to exercise                
               that power, and shall not be construed to contrivance                  
               [sic] of any constitutional state or federal law.                      
               “Schedule B” attached to the Fennel trust instrument lists             
          the property transferred to the trust as follows:                           
               Twenty-One (21) Silver Dollars (face value); Pre-1964                  
               Coinage of Account of the United States of America; One                
               (1) Ten Dollar Bill; Love & Kindness[;] HEWLETT PACKARD                
               PRINTER.                                                               
               “Attachment A” to the Fennel trust instrument is an undated            
          letter signed by Paul Jablonski and addressed to “The Settlor of            
          Fennel Trust”, stating: “I am in receipt of your letter dated 28            
          April 1994, appointing me Trustee of Fennel Trust, WHICH I HEREBY           
          ACCEPT IMMEDIATELY.”                                                        
               “Schedule C” attached to the Fennel trust instrument lists             
          the trust’s beneficiary as S&T Management Trust, which                      
          “surrendered” its “beneficial” interest in favor of Rosaria                 
          Jablonski.  Rosaria Jablonski is Paul Jablonski’s wife.                     



               7  Tarragon Trust is a petitioner in a related docket in               
          which the Commissioner has also filed a Motion to Dismiss for               
          Lack of Jurisdiction.  See docket No. 10709-00 and our Memorandum           
          Opinion at T.C. Memo. 2001-315.                                             





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