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allocation of Federal generation-skipping transfer (GST) tax to
the property bequests in decedent’s will; and (3) the fair market
value of decedent’s shares of stock of Royal Bancshares, Inc.1
FINDINGS OF FACT
The parties stipulated some facts, which we incorporate,
along with the associated exhibits, into our findings of fact.
Decedent died on September 26, 1997. Her domicile at death was
in St. Louis, Missouri. When the petition was filed, the
executor’s legal residence was in St. Louis, Missouri.
Decedent’s Will
On November 10, 1997, decedent’s will, dated July 10, 1990,
was admitted to probate. Section B of Article FIRST of
decedent’s will, which deals with the payment of transfer,
estate, inheritance, succession, and other death taxes, provides:
B. I direct my Personal Representative to pay,
out of my estate, all transfer, estate, inheritance,
succession and other death taxes (exclusive of any
generation-skipping transfer tax) payable, including
interest and penalties thereon, if any, assessed by the
United States or assessed by any state thereof or by
any foreign government against my estate or against any
gift, bequest or devise, or assessed by reason of the
inclusion in my estate for tax purposes of any life
insurance proceeds, annuity, joint property, property
held as a tenant by the entirety or any other property
or interest in property (other than property of any
trust created by me under an instrument which provides
otherwise with respect to the property of such trust);
1 Respondent represents that, after our resolution of the
above-stated issues, the parties will resolve whether the estate
is entitled to deductions of $49,433 for executor’s commissions
and $8,500 for accountant’s fees.
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