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FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference. At the
time that Conrad and Maria filed their petition at docket No.
14318-01, they resided in California. At the time that Carroll
and Donna filed their petition at docket No. 1344-02, they
resided in New York.
Background
Sidney Janis (Sidney), the father of petitioners Conrad
Janis (Conrad) and Carroll Janis (Carroll), owned and operated as
a sole proprietorship the Sidney Janis Gallery (gallery) in New
York City from 1948 until 1988. Pursuant to a trust agreement,
Sidney transferred the gallery to an irrevocable trust in April
1988. In the trust agreement, Sidney named himself, Conrad, and
Carroll as the trustees of the trust. Sidney retained an income
interest in the trust for his life as well as a general power of
appointment over the trust’s assets. At Sidney’s death, the
trust was to terminate, and any trust assets that Sidney had not
exercised his general power of appointment over were to be
distributed to Conrad and Carroll in equal shares. Sidney died
on November 23, 1989. In his will, Sidney named Conrad and
Carroll co-executors and sole beneficiaries of his estate.
Carroll obtained a bachelor of science degree as well as a
master’s degree in art history from Columbia University. Before
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