Estate of H.A. True, Jr. - Page 290




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          lists the transferred interests and compares the 1993 gift tax              
          notice values to amounts paid by the purchasers.                            
              B.  1994 Estate Transfers                                               
              Dave True died of a heart attack on June 4, 1994.  Before               
          his death, he had transferred substantially all his assets to his           
          living trust.  Under section 5.2 of the living trust, Dave True             
          reserved the power to appoint the trust estate at the time of his           
          death to “such persons, corporations or other entities and in               
          such shares and interests as I may specify by appropriate                   
          provisions in any instrument executed and acknowledged by me and            
          delivered to the [trustees of the living trust].”  On September             
          14, 1984, Dave True had exercised his power of appointment by               
          executing the appointment document.                                         
              Under the appointment document Dave True bequeathed to his              
          sons the maximum amount that could pass without estate tax by               
          reason of the unified credit (equally and free of trust) and the            
          remainder of the trust estate to a qualified terminable interest            
          property trust (QTIP trust) for Jean True.  At Jean True’s death            
          (or from the beginning, had Jean predeceased Dave), the balance             
          of the trust estate and any tangible personalty was to be divided           
          equally among his sons or their heirs.  However, before these               
          bequests were funded, and pursuant to the terms of the buy-sell             
          agreements, the trustees of the living trust sold Dave True’s               
          interests in the True companies to Jean True, Hank True, Diemer             






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