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power of appointment with respect to each trust. In this
connection, the trust instrument provided, in pertinent part:
3.1. Income and Principal. The Trustee is hereby authorized
to distribute all or as much of the net income or principal
or both of a separate trust to the beneficiary or to one or
more of the beneficiaries of such trust as the Trustee deems
to be in the best interests of said beneficiary or
beneficiaries.
3.2. Limited Powers of Appointment. The Grantor’s son may,
during his lifetime and upon his death, appoint all or any
part of the trust estate of each separate trust of which he
shall be a beneficiary to or for the benefit of any person,
persons, or charitable organization * * *
Kanter asserted that, by January 20, 1977, he had renounced
all beneficial interests in the Bea Ritch Trusts.
At some unknown point before 1987, 60 trusts (the various
JSK Trusts) were added as beneficiaries of the Bea Ritch Trusts.
Exhs. 135, 9187, 9269, 9270, 9271. The original and additional
beneficiaries of each of the Bea Ritch Trusts are set forth in
detail in appendix 17. Kanter was the trustee for each of the 60
additional trusts which became the beneficiaries of the Bea Ritch
Trusts. Exhs. 9187, 9269, 9270, 9271.
No evidence was introduced at trial as to terms of, or the
identity of the beneficiaries of, the 60 additional trusts that
became beneficiaries of the Bea Ritch Trusts. No evidence was
introduced at trial as to how the 60 trusts were appointed
beneficiaries of the Bea Ritch Trusts.
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