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were specifically bequeathed to the decedent's sister
(paragraph 5.02). It then directs the successor trustee,
in paragraph 5.03, to allocate one-half of the "remaining"
trust assets or property to a private charitable foundation
for the benefit of the charitable beneficiary. Paragraph
5.03 directs the charitable foundation to hold the church's
share for 5 years before distributing it in fee to the
church. Finally, paragraph 5.04 directs the successor
trustee make a distribution of property to the non-
charitable beneficiary "upon the death of the Grantor."
The trust agreement describes the share of the
noncharitable beneficiary which is to be distributed
upon the decedent's death as: "the remaining trust
property which remains after providing for all previous
distributions and for payment of all expenses of
administering such Trust in accordance with provisions
of paragraph 6.02 herein for bequests, debts, expenses,
and taxes of Grantor's estate". Thus, in computing the
one-half share to be distributed to the noncharitable
beneficiary 5 years before the charitable beneficiary
is to receive its share, paragraph 5.04 requires that the
decedent's bequests, debts, expenses, and death taxes be
taken into account. It appears that the trust agreement
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