Orneal and Martha Kooyers, et al. - Page 7

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          discretion to terminate any trust before the end of the 25-year             
          period and, at the end of the period, could renew the trust                 
          agreement for another period up to 25 years.                                
               Petitioners intended that 20 percent of the beneficial                 
          interest in the OMK Family Trust was to be held by their children           
          and 80 percent was to be held by P.I. Ministries.  Minutes of the           
          board of trustees of OMK Family Trust, dated November 17, 1995,             
          indicate that there were 100 beneficial units, of which 80 were             
          held by the OMK Charitable Trust5 and 20 were held by                       
          petitioners’ children.  Minutes of the board of trustees of the             
          OMK Company Trust, dated November 18, 1995, indicate that the OMK           
          Family Trust was the sole beneficiary of the OMK Company Trust.             
               Minutes of the board of trustees of the OMK Family Trust,              
          dated November 17, 1995, state that the beneficial certificates             
          convey no interest of any kind in the trust assets; convey no               
          voice in the management or control of the trust but do convey a             
          right to receive a pro rata share of “emoluments” that may be               
          distributed by the trustees.                                                







               5The minutes of the board of trustees of the OMK Family                
          Trust, dated Nov. 17, 1995, state that the trustees agreed to               
          create a private charitable foundation (a charitable trust) to              
          which units of beneficial interest were issued.  The declaration            
          of trust for the OMK Charitable Trust is not in the record.                 





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