Tarragon Trust - Page 6




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               Article Five “Power of Trustees”, section 5.5 of the                   
          Tarragon 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 Tarragon 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[;] 1 COMPUTER,                    
               KEYBOARD, MOUSE, & MONITOR.                                            
               “Attachment A” to the Tarragon trust instrument is an                  
          undated letter signed by Zola Sheehan for Cypress Management and            
          addressed to “The Settlor of Taragon Trust”, stating: “I am in              
          receipt of your letter dated 28 April 1994, appointing me Trustee           
          of Taragon Trust, WHICH I HEREBY ACCEPT IMMEDIATELY.”  A second             
          “Attachment A” to the Tarragon trust instrument is a similar                
          undated letter, this one signed by Paul Jablonski, again                    
          addressed to “The Settlor of Taragon Trust” and stating: “I am in           
          receipt of your letter dated 28 April 1994, appointing me Trustee           
          of Tarragon Trust, WHICH I HEREBY ACCEPT IMMEDIATELY.”                      
               “Schedule C” attached to the Tarragon trust instrument lists           



               6(...continued)                                                        
          Jurisdiction.  See docket No. 10710-00 and our Memorandum Opinion           
          at T.C. Memo. 2001-316.                                                     





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