Estate of Helen Christiansen, Deceased, Christine Christiansen Hamilton, Personal Representative - Page 3




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          the present value of that 7 percent annuity from the trust to the           
          foundation.  This depends on whether Hamilton’s undisclaimed                
          contingent-remainder interest in the trust requires disallowance            
          of that deduction.  The second question is whether the estate can           
          claim an increased charitable deduction for the increased value             
          of the disclaimed property passing directly to the foundation.              
                                  FINDINGS OF FACT2                                   
               Helen Christiansen, a lifelong South Dakotan, led a long and           
          remarkable life.  She was one of the first women lawyers in her             
          state and practiced there until the late 1950s, when she married            
          and became a full-time farmer.  She and her husband had one                 
          child, Christine Christiansen Hamilton.  Hamilton remains, as she           
          was when she filed the petition, a South Dakota resident.  Her              
          mother was domiciled in the state when she died.                            
               The Christiansens each owned and operated their own farming            
          and ranching businesses in central South Dakota for many years.             
          When her husband died in 1986, Christiansen added his operations            
          to her own.  Christiansen’s daughter, like her mother, became               
          well educated, graduating from Smith College and then earning an            
          MBA from the University of Arizona.  And like her mother, she               
          decided on a life back home in South Dakota.  She married a                 



               2 The parties stipulated to most of the key facts and                  
          exhibits, and insofar as they are relevant to our analysis, we              
          have adopted the trial Judge’s findings of fact on the others.              





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