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William’s employment with Reliance continued until his death
in 1998 by which point William was serving as chairman of
Reliance’s board of directors. Throughout his long business
career with Reliance, William acquired additional privately held,
unregistered shares of Reliance common stock.
Shortly before William’s death in 1998, William and decedent
established the Gimbel Family Trust (the Trust), and William
transferred to the Trust, among other assets, all of his shares
of Reliance common stock.
Upon William’s death, the Trust was divided into two
subtrusts: A marital trust and decedent’s survivor trust
(collectively, “the Trusts”).
Includable in decedent’s gross estate (the estate) were the
shares of Reliance common stock (the estate’s Reliance shares)
held by the Trusts, by decedent’s account in Reliance’s employee
stock ownership plan (ESOP), by decedent’s IRA, and by decedent
individually, as follows:
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Last modified: May 25, 2011