- 10 - following family trusts were formed: The DAS Family Trust, the DAC Family Trust, and the RMA Family Trust. Mr. Goldman was named the trustee of the DAS and DAC family trusts, and Mr. Rubin was initially named the trustee of the RMA family trust.12 Under the agreement for each family trust, the trustee was granted the following power: During Ida’s lifetime the Trustees in their discretion shall pay the net income and principal of the trust property to Ida during her lifetime for her benefit and may also make payments to any one or more of her * * * [children: Mr. Richard Abraham, Ms. Cawley, and Ms. Slater and their] issue and the spouse of * * * [children] to utilize gift tax exclusions. Upon her death, the trustee was to transfer the balance of the principal of the trust property to separate “family trusts” for the benefit of decedent’s children, Mr. Richard Abraham, Ms. Cawley, and Ms. Slater, or in accordance with each child’s general power of appointment. Initially, with respect to the DAS and DAC FLPs, decedent held a 98-percent limited partnership interest, the corporate general partners, DAS, Inc., and DAC, Inc., each held a 1-percent interest, and Ms. Cawley and Ms. Slater each held a 1-percent interest.13 Similarly, decedent initially held a 99-percent 12Mr. Richard Abraham and his wife, Jacqueline, became cotrustees of the RMA Family Trust on Jan. 15, 1996. 13Except for a letter discussed infra, there is no indication in the record that Ms. Cawley and Ms. Slater paid any consideration for 1-percent interests in the FLPs. See infra (continued...)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