Estate of Ida Abraham, Deceased, Donna M. Cawley, and Diana A. Slater, Administratrixes - Page 10

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          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...)           




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