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outside of this Will pursuant to the terms of the govern-
ing instrument)", simply recognizes that, in certain
circumstances, death taxes can be paid from the trust.
It does not express the decedent's intent that all death
taxes be paid from the trust.
We agree with respondent that under paragraph 1.02 of
the will, the death taxes attributable to the decedent's
death are to be paid from his residuary estate as an
administration expense, but, if the residuary assets are
not sufficient to pay all of the decedent's debts,
expenses, and death taxes, then paragraph 1.03 of the will
provides that the "Executor shall certify to the Trustee
* * * the amount of the insufficiency, which amount shall
be paid out of the property of the trust as provided in
that instrument." If the decedent had intended that all
death taxes be paid from the trust, as the estate contends,
then there would be no point in requiring the executor to
certify the amount of any "insufficiency" to the trustee of
the trust, as provided by paragraph 1.03 of the will.
We also agree with respondent that the decedent's will
provides that there is to be no apportionment of death
taxes. Paragraph 1.02 of the will states that the
decedent's death taxes "shall be paid out of my Residuary
Estate as an administration expense and shall not be
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