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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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