Estate of Mildred Green, Deceased, Thomas R. Green, Executor - Page 3

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               such taxes shall not be charged against nor deducted                   
               from any such gift, bequest, devise, life insurance                    
               proceeds, annuity, joint property, tenancy by the                      
               entirety property or other property or interest in                     
               property, upon or by reason of which such taxes are                    
               assessed and paid.  Notwithstanding the foregoing, I                   
               direct my Personal Representative to pay, out of my                    
               estate, any tax imposed under Chapter 13 of the                        
               Internal Federal Revenue Code on property transferred                  
               in a “direct skip,” as defined in Section 2612(c) of                   
               the Code; such tax shall not be deducted from or reduce                
               the gift, bequest or devise which constitutes a “direct                
               skip.”                                                                 
          Article SECOND of decedent’s will provides for the disposition of           
          all her tangible personal property.  Article THIRD gives one-half           
          of the “rest, residue and remainder” of decedent’s property to              
          the Lubin-Green Foundation, which is a charity for purposes of              
          section 2055.2  Article FOURTH gives the other one-half of the              
          “rest, residue and remainder” of decedent’s property in trust for           
          her grandchildren.                                                          
               At death, decedent was survived by three grandchildren, each           
          of whom was an eligible beneficiary under Article FOURTH of                 
          decedent’s will.                                                            
          Decedent’s Shares of Common Stock of Royal Bancshares, Inc.                 
               At death, decedent owned 3,276 of the 64,372 shares of                 
          issued and outstanding common stock of Royal Bancshares, Inc.               
          (RBI).  Decedent’s shares represented 5.09 percent of the                   
          outstanding shares of RBI; hers was the fifth largest holding of            


               2 Unless otherwise indicated, all section references are to            
          the Internal Revenue Code as amended, and all Rule references are           
          to the Tax Court Rules of Practice and Procedure.                           




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Last modified: May 25, 2011