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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