Estate of Eleanor T.R. Trotter - Page 6

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          accruing to him under Arkansas law.  No consideration was paid to           
          decedent or Mr. Trotter in connection with the transfer.                    
               Following the trust’s creation, none of the beneficiaries              
          attempted to exercise a right of withdrawal.  Decedent and Mr.              
          Trotter continued to live in the condominium as their primary               
          residence until decedent’s death on January 31, 1996.  No rental            
          payments were made by decedent and/or Mr. Trotter to the trust              
          from December 17, 1993, to January 31, 1996.  During this period,           
          decedent paid all occupancy expenses related to the condominium,            
          including maintenance expenses, utilities, property taxes,                  
          condominium fees, and premiums for insurance coverage.  No bank             
          account was maintained by or for the trust, and, with the                   
          exception of the above-referenced transfer of title to the                  
          condominium, the trust did not receive or distribute any cash or            
          other property during this time.                                            
               As previously indicated, decedent died on January 31, 1996.            
          Thereafter, for a period of 3 months, Mr. Trotter continued to              
          reside in the condominium.  He made no rental payments to the               
          trust with respect to his occupancy.  During this period, and               
          until at least June of 1996, the trust expended no funds for                
          maintenance, utilities, taxes, or fees; received no further cash            
          or property; and distributed no assets for the benefit of the               

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