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John Rector, who signed the return as coexecutor of the estate,
had extensive expertise in financial matters. He knew, or at
least should have known, about the omission in his capacity as
cotrustee of decedent’s 1991 revocable trust, as coexecutor of
decedent’s estate, and most significantly as the donee of
one-half of the $595,000. The estate makes no showing of
reasonable cause or good faith with respect to the omission.
_______________________________________________
We have considered all arguments by petitioner for holdings
contrary to those reached herein and find those agreements not
discussed herein to be without merit.
Decision will be entered
under Rule 155.
11(...continued)
meet any burden of production respondent may have with respect to
his determination of negligence.
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Last modified: March 27, 2008