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to remove the art collection from his estate), and the amount of
estate tax on a $5 million taxable estate. Decedent told Mr.
Newman that when decedent had the answers to his questions he
(decedent) would prepare a new will.
On April 3, 1993, decedent wrote a letter to Mr. Newman.
Decedent understood that there would be GST tax if he made Bar
his “sole heir” and that there would be gift taxes associated
with giving his art to Bar (so he decided not to do this).
Decedent’s C.P.A. had given decedent round numbers on what Bar
would inherit after taxes. On the basis of the numbers his
C.P.A. provided, decedent felt that Bar would be able to generate
enough income from his inheritance after taxes to maintain
Hundred Acres, its buildings, and its contents. Decedent,
however, wanted a second opinion from Mr. Newman on how much Bar
would inherit after taxes to make sure Bar would have enough to
maintain Hundred Acres. Decedent wanted a new will as soon as
possible to ensure that Hundred Acres would not “be lost”.
On April 8, 1993, decedent wrote a letter to Mr. Newman.
Decedent wrote: “I’ll sure be glad when we have our two Wills
finalized so Bar can keep Hundred Acres and the Big House a kind
of monument to me. Instead of a stone in a cemetery.”
On April 13, 1993, decedent wrote a document entitled “My
Will - An Explanation”. This document is similar to his March
19, 1988, letter to Bar and Barney. It stated as follows:
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