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Ms. Mattson, as successor trustee of the Engelman Living
Trust, then distributed from Trust A to Trust B property worth
approximately $617,317, representing the appreciated value of the
disclaimed assets on the date of the distribution. After this
allocation, property valued at approximately $930,557 as of
decedent’s date of death remained in Trust A. On July 2, 1998,
checks written on the account of “Engelman Living Trust B” were
issued to the following beneficiaries: To the Estate of Helen
Adams, $50,000; to Carol L. Engelman, $30,000; to Jerrold W.
Engelman, $10,000; to Alan Engelman, $10,000; to Yale University,
$5,000; and to the American Cancer Society, $5,000. In August of
1998, a transmittal letter referencing “the balance of the B
Trust portion of the Engelman Trust” and a check in the amount of
$432,901.41 were sent to the State of Israel.
Thereafter, in December of 1998, a Form 706, United States
Estate (and Generation-Skipping Transfer) Tax Return, was filed
on behalf of decedent’s estate. The reported value of the gross
estate, $936,476 as of the alternate valuation date, excluded the
disclaimed assets. The return claimed a charitable deduction of
$285,777, comprising $95,259 each to the American Cancer Society,
the University of California at San Diego, and the City of Hope.
The Form 706 also reported, with respect to individual
noncharitable beneficiaries, that Sharon Commings received
$95,529 and Jeffrey McCoy received $535,565 from the estate.
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