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On December 30, 1996, decedent created the Cynthia F.
Bongard Qualified Terminable Interest Property Trust (QTIP
Trust). The QTIP Trust agreement was drafted by Mr. Fullmer.
Gary Bongard (decedent’s brother) and Gary Brown (decedent’s
friend) were appointed trustees of this trust. The named
beneficiaries of QTIP Trust were Cynthia Bongard, decedent’s
children, and their issue. On March 15, 1997, QTIP Trust was
funded by decedent with 71,319 class A governance and 71,319
class A financial units in WCB Holdings.
Decedent formed the Wayne C. Bongard Revocable Trust
(Revocable Trust) on December 28, 1996. Decedent appointed
himself trustee, Mr. Bernards successor trustee, and Mark Bongard
second successor trustee. According to decedent’s last will and
testament dated December 28, 1996, all of his property was to go
to the Revocable Trust, except his personal property was to go to
Cynthia Bongard.
Decedent’s funding of GC Trust, CH Trust, and QTIP Trust
changed the ownership interests in WCB Holdings so that they were
held as follows:
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