-20-
Dinneen had come up with the idea of creating a Delaware business
trust in which decedent held a minority interest and served as
trustee, while the remaining interests would be held for the
benefit of his children and grandchildren by WTC trusts of which
decedent was the direction or consent adviser. The participants
agreed to pursue this idea, and decedent authorized Mr. Sweeney
to contact representatives of WTC to discuss the joint creation
of a business trust. They also reviewed at the meeting a
computation prepared by Mr. Dinneen reflecting the estimated
difference in Federal estate tax and net inherited amount under
decedent’s current estate plan and under a plan where a portion
of his assets would be placed into an entity subject to minority
and marketability discounts.
In early February 1997, on decedent’s behalf, Mr. Sweeney
met with representatives of WTC to determine whether the company
would consider being involved with decedent in forming a Delaware
business trust and, if so, under what conditions. Specifically,
on February 5, 1997, Mr. Sweeney met with George W. Helme IV,
senior vice president and head of the trust department of WTC.
Mr. Helme indicated that, in concept, the company was willing to
participate, and he directed Mr. Sweeney to speak with the legal
staff of the trust department regarding details. Mr. Sweeney
reported these developments to decedent in a letter dated
February 6, 1997.
Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 NextLast modified: May 25, 2011