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8. Mr. Richard Abraham, Ms. Cawley, and Ms. Slater shall
share “pro rata” all gift and estate tax liabilities of decedent.
Decedent’s estate plan evolved in numerous steps and
employed the use of many entities:6
(1) Three separate real estate trusts were formed to hold
the real property interests:7 (a) The DAC Tyngsboro Real Estate
Trust was formed on October 1, 1995, naming Ms. Cawley as
trustee, and on October 6, 1995, that trust was deeded a one-
half, undivided interest in the Tyngsboro property; (b) the RMA
Walpole Real Estate Trust was formed on October 1, 1995, naming
Mr. Richard Abraham as trustee, and on that day that trust was
deeded the Walpole property;8 and (c) the DAS Real Estate Trust
was formed on October 1, 1995, naming Ms. Slater as trustee, and
on October 6, 1995, that trust was deeded a one-half, undivided
interest in the Tyngsboro property.9 On the date that the
Tyngsboro property was transferred to the DAS and the DAC real
6Decedent’s estate plan, which benefited Mr. Richard
Abraham, differed slightly from those of Ms. Cawley’s and Ms.
Slater’s, and where relevant, we shall indicate any substantive
differences. However, most of the terms in the documents which
created the entities/structures herein discussed are
substantially similar.
7The parties stipulated that certain real properties were
“placed” in the FLPs.
8As discussed infra, the Smithfield property was deeded to
an FLP.
9Decedent, through her coguardians, deeded the properties to
the real estate trusts.
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