Estate of Ida Abraham, Deceased, Donna M. Cawley, and Diana A. Slater, Administratrixes - Page 3

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          decedent on Schedule M, Bequests, etc., to Surviving Spouse, on             
          his Form 706, United States Estate (and Generation-Skipping                 
          Transfer) Tax Return.  Among those assets bequeathed to decedent            
          were the following:  (1) Real properties consisting of ice and              
          roller skating rinks collectively known as the Tyngsboro                    
          property; (2) the real property known as the Walpole property,              
          which was comprised of a lumber yard; and (3) the real property             
          known as the Smithfield property, which also had an ice skating             
          rink.  Mr. Abraham, Sr.’s will was contested, and the family                
          entered into an agreement to compromise his will, which the                 
          probate court accepted.2                                                    
               On March 10, 1993, decedent was placed under a guardianship            
          in a proceeding docketed as In re: Guardianship of Ida Abraham,             
          Docket No. 92P 0589 in the Commonwealth of Massachusetts Probate            
          and Family Court.3  At some point, Mr. Peter F. Zupcofska, Esq.,            
          was appointed guardian ad litem for decedent.  On June 22, 1993,            
          the probate court appointed Ms. Cawley and Mr. Ira A. Nagel as              
          permanent guardians of the property and estate of decedent.4  On            


               2At some point between the filing of the petition in this              
          case and the execution of the stipulation of facts, decedent’s              
          son, Mr. Nicholas A. Abraham, decided to forgo any interest he              
          had in his mother’s estate.                                                 
               3Apparently, decedent suffered from the effects of                     
          Alzheimer’s disease.                                                        
               4The appointment of guardians was in accordance with the               
          terms of Mr. Abraham, Sr.’s compromised will.                               




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