-13-
charity annually of 5 percent of the value of the trust assets.
The total value of the trust fund was to be an amount which would
produce a charitable deduction for the charitable lead trust
sufficiently large to leave a taxable estate equal to decedent’s
unused generation-skipping transfer tax exemption. At the
termination of the charitable interest, specified amounts were to
be distributed to grandchildren born after Mrs. Schutt’s death
and to then-living issue of any predeceased grandchild.
Assets not distributed under the just-described provisions
were to be held in trust and to be paid at the sole discretion of
the trustee for the support, maintenance, education, care, and
welfare of then-living grandchildren of decedent and then-living
issue of any grandchild dying prior to the termination of the
charitable lead. This trust was to terminate upon the earlier of
the death of decedent’s last-surviving grandchild or 110 years
after decedent’s death. At that time, the corpus was to be
distributed outright, per stirpes, to decedent’s then-living
great-grandchildren and to issue of any predeceased great-
grandchild.
The special trust was to be created by setting aside $2
million. Until the death of the last to die of decedent’s
children, income could be paid to any then-living child in the
discretion of the trustee, so long as the trustee was not a child
of decedent. Following the death of the last to die of
Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 NextLast modified: May 25, 2011