Estate of Marie A. Maniglia, Deceased, Joseph S., Maniglia, Executor - Page 5

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               On December 23, 1985, the decedent refinanced the property             
          with a $350,000 loan from the Winter Hill Federal Savings & Loan            
          Association.  The mortgage on the property securing the loan was            
          recorded in the registry.  Immediately before recording the                 
          mortgage, Joseph S. Maniglia, as trustee of the Fam-Trust,                  
          conveyed the property to the decedent.  Immediately after                   
          recording the mortgage, the decedent reconveyed the property to             
          Joseph S. Maniglia as trustee of the Fam-Trust.  Both conveyances           
          were recorded in the registry.                                              
               Mortgage interest on the refinanced loan was reported to the           
          decedent.  The City of Boston issued real estate tax bills for              
          the property to “MANIGLIA JOSEPH S TRST OF FAM TR.”  The property           
          was insured in the name of “FAM Trust, Joe Maniglia Tr.”                    
               From 1978 through 1999, Federal partnership returns were               
          filed in the name of “Family Trust”.  From 1996 through 1999,               
          Massachusetts State partnership returns were filed in the name of           
          “Family Trust”.  For taxable years 1996 through 1999, the                   
          partnership filed Schedules K-1, Partner’s Share of Income,                 
          Deductions, Credits, etc., indicating that the decedent and                 
          Joseph S. Maniglia each owned a 50-percent interest in the                  
          partnership and reporting 50 percent of the partnership’s income            
          to each partner.  For taxable years 1996 through 1999, the                  
          decedent and Joseph S. Maniglia each reported the income reported           
          on the Schedules K-1 on their individual Federal income tax                 






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