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share then owned. Later in 1956 and in 1957, Emma transferred 75
voting shares to Louise, 150 nonvoting shares to Emile, and 150
nonvoting shares to each grandchild. Louise also transferred
during that time 150 shares of nonvoting stock to Emile and 150
nonvoting shares to each grandchild.
Upon Emma’s death in 1958, her remaining shares were placed
in the Emma Haffner Trust (Emma’s Trust).4 Louise was the
executrix of Emma’s estate and the named trustee of Emma’s Trust.
On February 4, 1959, Emma’s Trust transferred 75 of its voting
shares to Louise, and Louise transferred 150 of her nonvoting
shares to Emile and 150 nonvoting shares to each grandchild. The
voting shares were then owned 148 by John’s Trust, 150 by Emma’s
Trust, and 602 by Louise. The nonvoting shares were owned 592 by
John’s Trust, 300 by Emma’s Trust, 8 by Louise, 450 by Emile, and
450 by each grandchild.
On August 1, 1959, Emma’s Trust transferred its 150 voting
shares to Louise. On February 14, 1961, Louise transferred from
John’s Trust to herself the remaining 148 voting shares and 592
nonvoting shares (the 1961 transfer) as reimbursement for estate
taxes which she had paid personally on behalf of John’s estate.
After the 1961 transfer, Louise owned all 900 voting shares and
600 of the 3,600 nonvoting shares. Emma’s Trust owned 300 of the
4 The stipulation of facts incorrectly lists this trust as
the Emma Fournier Trust.
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Last modified: May 25, 2011