- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011