HomeMy WebLinkAbout05-21-08COMMONWEALTH OF P~INSYLVANIA
DEPARTMENT OF REVENUE
BUREAU OF INDIVIDUAL TAXES
DEPT. 280601
HARRISBURG, PA 1 7 1 28-0601
RECEIVED FROM:
PENNSYLVANIA
INHERITANCE AND ESTATE TAX
OFFICIAL RECEIPT
N0. CD 009769
WADDINGTON THOMAS V
1540 MCCORMICK AVENUE
MECHANICSBURG, PA 17055
ford
ESTATE INFORMATION: ssrv: zas-4s-3s72
FILE NUMBER: 2107-0869
DECEDENT NAME: WADDINGTON ANNE W
DATE OF PAYMENT: 05/22/2008
POSTMARK DATE: 05/21 /2008
COUNTY: CUMBERLAND
DATE OF DEATH: 08/28/2007
REMARKS: RECEIPT TO ATTY
CHECK# 4972
SEAL
ACN
ASSESSMENT AMOUNT
CONTROL
NUMBER
101 ~ $5,625.62
TOTAL AMOUNT PAID:
INITIALS: WZ
REV-1162 EX111-961
55,625.62
RECEIVED BY: GLENDA FAI3NER STRASBAUGH
REGISTER OF WILLS
REGISTER OF WILLS
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7
Last Will
of
ANNE W, WADDINGTON
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I, ANNE w. WADDINGTON, the Testatrix, a resident of Cumberland County, Pennsylvania, declare
that this is my Last Will. I hereby revoke all my previous wills and codicils.
Article One
Introductory Provisions
Section 1. Marital Status
I am currently married to HAROLD T. WADDINGTON, and all references 1'.o my Spouse in this will
are to HAROLD T. WADDINGTON.
Section 2. Children
All references to "my children", subject to the exclusion of any child under subsequent
provisions of this Section 2, are to all of the children so identified in this Section, 2, but only to
those children and any children born to or adopted by me subsequent to the execution of this, my
Last Will.
a. The names and birth dates of my children are:
Name ~ ate
JOHN F. WADDINGTON March 08, 1951
RUTH A. PATRICK C?ctober 22, 1957
THOMAS V. WADDINGTON January 26, 1960
Article Two
Appointment of My Personal Represent:~tives
Section 1. Nomination of My Personal Representatives
I appoint the following to be my Personal Representative(s) in the order of priority in which their
names appear:
HAROLD T. WADDINGTON AND THOMAS V. WADDINGI'ON; THEN
IF HAROLD T. WADDINGTON IS UNABLE OR UNWII.,LING TO SERVE,
THOMAS V. WADDINGTON AND JOHN F. WADDINGTON AND
RUTH A. PATRICK, OR THE SURVIVOR(S) OF THEM; THEN
HERSHEY TRUST COMPANY
If, for any reason, the Personal Representative(s) named above are unable or unwilling to serve,
the next successor Personal Representative(s) shall serve in the order of priority listed until the
list has been exhausted. Unless otherwise specified, if Co-Personal Representatives are serving,
the next named successor Personal Representative shall serve only niter all of the Co-Personal
Representatives cease to act as Personal Representatives.
Section 2. Waiver of Bond
No bond or undertaking shall be required of any Personal Representatiive nominated in this Last
Will.
Section 3. General Powers
My Personal Representative shall have full authority to administer my estate under the laws of the
Commonwealth of Pennsylvania relating to the powers of fiduciaries. My Personal Representative
shall have the power to administer my estate under the Pennsylvania Probate, Estates and "
Fiduciaries Code.
Article Three
Disposition of My Property
Section 1. Estate Planning Letter or Memorandum
To the extent permitted by state law and not necessary to fully utilize my Unused Applicable
Credit Equivalent, my Personal Representative shall distribute such of my personal or household
items to such persons as I may direct by a written instrument signed by me and delivered to my
Personal Representative.
Section 2. Distribution to My Revocable Living Trust
I give all the rest, residue and remainder of my property of whatever nature and kind and
wherever located to the then acting Trustee(s) of my revocable living trust of which I am a
Trustor known as the:
ANNE W. WADDINGTON LIVING TRUST,
dated November 20, 2000, and any amendments thereto.
I executed said revocable living trust prior to the execution of this Last V~Jill.
Section 3. Alternate Disposition
If my revocable living trust is not in effect for any reason, I give al]. of my property to my
Personal Representative under this will as Trustee who shall hold, administer and distribute my
property as a testamentary trust the provisions of which are identical to those of my revocable
living trust on the date of execution of this Last Will, or as thereafter ame>nded.
Article Four
Death Taxes
Section 1. Definition of Death Taxes
The term "death taxes," as used in this will, shall mean all inheritance, estate, succession, and
other similar taxes that are payable by any person on account of that pe:rson's interest in the estate
of the decedent or by reason of the decedent's death, including penalties and interest, but
excluding the following:
a. Any additional to the federal estate tax for any "excess retirement accumulation"
under Internal Revenue Code Section 4980A.
b. Any additional tax that may be assessed under Intern~a Revenue Code Section
2032A or 2057; and
c. Any federal or state tax imposed on a Generation Skipping Transfer, as that term
is defined in the federal tax laws, unless the applicable tax statutes provide that
the Generation Skipping Transfer Tax is payable directly out of the assets of my
gross estate.
Section 2. Payment of Death Taxes
Pursuant to the terms of my revocable living trust, all death taxes whether or not attributable to
property inventoried in my probate estate shall be paid by the Trustee from my Trust. However,
if my Trust does not exist at the time of my death or if the assets of my Trust are insufficient to
pay the death taxes in full, I direct my Personal Representative to pay any death taxes that cannot
be paid by my Trustee from the assets of my probate estate by equitably prorating and
apportioning those taxes among the beneficiaries of this will.
Unless specifically provided otherwise in my Trust, all death taxes inctured by reason of assets
being transferred outside of my Trust or probate estate shall be assessed against those persons
receiving such property.
Section 3. Waiver of Right of Reimbursement Under Codle Section 2207A
I hereby waive my estate's right of reimbursement under Code Section 22.07A.
Article Five
General Provisions
Section 1. No Contest Clause
If any person or entity singularly or in conjunction with any other person or entity, directly or
indirectly, contests in any court the validity of this Last Will including any codicils thereto, then
the right of that person or entity to take any interest in my estate shall cease and the demise of
that person (and his or her descendants) or entity shall be deemed to have occurred prior to mine.
Section 2. Captions
The captions of Articles, Sections and Paragraphs used in this Last Will are for convenience of
reference only and shall have no significance in the construction or interpretation of this Last
will.
Section 3. Severability
Should any of the provisions of this Last Will be for any reason declared invalid, such invalidity
shall not affect any of the other provisions of this will and all invalid ;provisions shall be wholly
disregarded in interpreting this Last Will.
Section 4. Governing Law
This Last Will shall be construed, regulated and governed by and in accordance with the laws of
the Commonwealth of Pennsylvania.
I signed this, my Last Will, on ®C~ ~ _ Zod~
.~2 ~
W. WADDINGT N
ATTESTATION CLAUSE
On this ®~~ ~ _ ~~~~ _, ANNE W WADDINGTON, Testatrix, personally Published and
Declared the foregoing instrument, as and for her Last Will and Testament, in the presence of
each of us and all of us together, who, at her request, in her presence, and in the presence of each
other, also signed the said instrument as witnesses. We further state that each of us believes that
at the time she executed the foregoing instrument he was of sound mind and memory, of lawful
age, and did so execute it as her own free act and deed and not undf;r the constraint or undue
influence of any person.
Witness
Street Address
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City, S t ,Zip
Witness
Street Address
City, St e, ip
COMMONWEALTFI OF PENNSYLVANIA
COUNTY OF DAUPHIN
We, ANNE W. WADDINGTON, ~ a~.i ~ G ~. ,~_ and
~~l'~L~Gt~ ~ ,the Testatrix and the witnesses, respectively, whose
names are signed to the attached or foregoing instrument, being duly first sworn, do hereby
declare to the undersigned authority that we were present and saw fhe Testatrix sign and execute
the foregoing instrument as her Last Will; that the Testatrix signed it willingly, or directed
another to sign it for the Testatrix, that it was executed as her fr+~e and voluntary act for the
purposes therein expressed; that each subscribing witness in the presence and hearing of the
Testatrix signed the Last Will as a witness; and that to the best of our knowledge the Testatrix
was at the time of sound mind and memory, of lawful age, and mnder no constraint or undue
influence.
a ~ ~
W. ADDINGTON
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Witness
SUBSCRIBED, SWORN TO and ACKNOWLEDGED before me, a notary public, by
ANNE W. WADDINGTON the Testatrix, and ~ aK: ~. ,~=.1~1~~ and
~~ ,the witnesses, on this Q~~ $ _ ~~$~
otary Public
(SEAL)
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The First Amendment
to the
Anne W. Waddington Living Trust
On November 20, 2000, I, Anne W. Waddington, signed the Anne W. Waddington Living
Trust, more formally known as:
Anne W. Waddington and Harold T. Waddington, Trustees, or their successors in
trust, under the Anne W. Waddington Living Trust, dated November 20, 2000, and
any amendments thereto.
Pursuant to Article Four of my Living Trust, which permits me to amend my Living Trust in
writing at any time, I now wish to amend my Living Trust as follows:
Article Eleven of my Living Trust is hereby revoked in its entirety and amended as follows:
Division and Distribution of Trust Property
Section 1. Division of Trust Property Into Shares
While, to the extent practical, maintaining any previously established Generation Skipping
Transfer Tax ratios relative to trust property, my Trustee shall divide, into separate shares, all of
my Trust Estate not previously distributed under the preceding Articles of my Trust Agreement
(and for purposes of determining such division and subsequent distributions shall take into
account the exclusion of any descendant as maybe directed in Article One) as follows:
Beneficiary Name
JOHN F. WADDINGTON
RUTH A. PATRICK
THOMAS V. WADDINGTON
The trust shares shall beheld, administered and distributed as follows:
a. Distribution of Trust Share for ,TORN F. WADDINGTON
The trust share set aside for JOHN F. WADDINGTON shall be held, administered and
distributed as follows:
1. Distributions of Net Income
My Trustee shall immediately pay to, or apply for the benefit of,
such beneficiary, all net income from such beneficiary's trust share,
free of trust.
1
Share
1/3
1/3
1/3
2. Distributions of Principal
My Trustee, in my Trustee's discretion, shall pay to, or apply for the
benefit of, such beneficiary, so much of the principal from such
beneficiary's trust share as my Trustee deems advisable for such
beneficiary's health, education, maintenance or support.
At the death of the second to die of my spouse and me, my Trustee
shall distribute 1!2 of the balance of such beneficiary's trust share to
such beneficiary, free of trust.
Five years of the death of the second to die of my spouse and me, my
Trustee shall distribute the balance of such beneficiary's trust share
to such beneficiary, free of trust.
3. Distribution on Death of Beneficiary
If such beneficiary should die prior to the time that a distribution is
directed to be made, such beneficiary's interest in such trust share
shall lapse and my Trustee shall distribute the balance of the trust
share to such beneficiary's then living descendants, per stirpes.
If such beneficiary has no then living descendants, my Trustee shall
distribute such beneficiary's trust share to my then living
descendants, per stirpes.
If I have no then living descendants, my Trustee shall distribute the
balance of the trust share as provided in the Articles that follow.
b. Distribution of Trust Share for RUTH A. PATRICK
The trust share set aside for RUTH A. PATRICK shall be held, administered and
distributed as follows:
1. Distributions of Net Income
My Trustee shall immediately pay to, or apply for the benefit of,
such beneficiary, all net income from such beneficiary's trust share,
free of trust.
2. Distributions of Principal
My Trustee, in my Trustee's discretion, shall pay to, or apply for the
benefit of, such beneficiary, so much of the principal from such
beneficiary's trust share as my Trustee deems advisable for such
beneficiary's health, education, maintenance or support.
2
At the death of the second to die of my spouse and me, my Trustee
shall distribute 1/2 of the balance of such beneficiary's trust share to
such beneficiary, free of trust.
Five years of the death of the second to die of my spouse and me, my
Trustee shall distribute the balance of such beneficiary's trust share
to such beneficiary, free of trust.
3. Distribution on Death of Beneficiary
If such beneficiary should die prior to the time that a distribution is
directed to be made, such beneficiary's interest in such trust share
shall lapse and my Trustee shall distribute the balance of the trust
share to such beneficiary's then living descendants, per stirpes share
to such beneficiary's then living descendants, per stirpes.
If such beneficiary has no then living descendants, my Trustee shall
distribute such beneficiary's trust share to my then living
descendants, per stirpes:
If I have no then living descendants, my Trustee shall distribute the
balance of the trust share as provided in the Articles that follow.
c. Distribution of Trust Share for THOMas v. WADDINGTON
The trust share set aside for THOMAS v. WADDINGTON shall be held, administered
and distributed as follows:
1. Distributions of Net Income
My Trustee shall immediately pay to, or apply for the benefit of,
such beneficiary, all net income from such beneficiary's trust share,
free of trust.
2. Distributions of Principal
My Trustee, in my Trustee's discretion, shall pay to, or apply for the
benefit of, such- beneficiary, so much of the principal from such
beneficiary's trust share as my Trustee deems advisable for such
beneficiary's health, education, maintenance or support.
At the death of the second to die of my spouse and me, my Trustee
shall distribute 1/2 of the balance of such beneficiary's trust share to
such beneficiary, free of trust.
Five years of the death of the second to die of my spouse and me, my
Trustee shall distribute the balance of such beneficiary's trust share
to such beneficiary, free of trust.
3. Distribution on Death of Beneficiary
If such beneficiary should die prior to the time that a distribution is
directed to be made, such beneficiary's interest in such trust share
shall lapse and my Trustee shall distribute the balance of the trust
share to such beneficiary's then living descendants, per stirpes share
to such beneficiary's then living descendants, per snipes.
If such beneficiary has no then living descendants, my Trustee shall
distribute such beneficiary's trust share to my then living
descendants, per stirpes.
If I have no then living descendants, my Trustee shall distribute the
balance of the trust share as provided in the Articles that follow.
Section 2. Distributions to Underage or Incapacitated Beneficiaries
Notwithstanding any provision to the contrary in this Article Eleven and subject to Section 2 of
Article Fifteen, if any beneficiary otherwise entitled to receive a distribution of trust property is
under the age of 40 years or is incapacitated, as defined in Article Fifteen, my Trustee shall retain
and administer such beneficiary's trust share for such beneficiary's benefit pursuant to the
following provisions of this Article Eleven:
a. Incapacitated Beneficiary
If such beneficiary's trust share is being held under this Section 2 due to such
beneficiary's incapacity (as defined in Article Fifteen) then, only during the term
of such incapacity, such beneficiary's trust share shall be administered according
to the Special Needs Provisions of Article Fifteen. 1_Tpon the beneficiary's
regaining capacity (as determined under Article Fifteen) the following provisions
of this Article Eleven shall apply.
b. Underage Beneficiary
If such beneficiary's trust share is being held under this Section 2 due to such
beneficiary's being under the age of 40, such beneficiaryy's trust share shall be
administered as follows:
1. My Trustee's Discretion
My Trustee shall pay to, or apply for the benefit of, such beneficiary,
so much of the net income and principal of such beneficiary's bust
share as my Trustee, in my Trustee's discretion, deems proper
considering all other resources then known to be available to such
beneficiary.
2. Payments Made to Beneficiary or Personal
Representative
My Trustee is authorized to make payments under this Section 2.b
directly to the beneficiary, to the beneficiary's Personal
Representative or to any other person my Trustee may deem proper
to be used for the benefit of the beneficiary.
3. Trustee's Decisions Are Final
All decisions by my Trustee as to whom. my Trustee makes
payments, the purposes for which payments are made and the
amounts to be paid out of any trust share are within my Trustee's
discretion.
4. Undistributed Net Income
All undistributed net income shall be accumulated and added to the
principal of the trust share.
Section 3. Termination and Distribution as to Underage or Incapacitated
Beneficiary
Unless distributions from a trust share are withheld pursuant to Section 1 of Article Fifteen, my
Trustee shall distribute the trust share to the respective beneficiary of the share being held under
Section 2 of this Article Eleven on the latest to occur of (i) the date upon which such beneficiary
reaches the age of 25 years; (ii) one-fourth (1/4) of the trust share when such beneficiary attains
the age of 25 years, one-half (1/2) of the balance of the trust share when such beneficiary attains
the age of 30 years, and the balances of the trust share when such beneficiary attains the age of 40
years; or (iii) when such beneficiary is no longer incapacitated, as determined pursuant to the
provisions of Article Fifteen.
Section 4. Death of Incapacitated or Underage Beneficiary
Subject to the provisions of preceding Sections of this Article Eleven, if any beneficiary whose
trust share is being held in trust under such Sections dies before the complete distribution of such
beneficiary's trust share, the beneficiary's interest in such trust share shall lapse and my Trustee
5
shall distribute such beneficiary's trust share to such beneficiary's then living descendants, per
stirpes; or, if none, to such beneficiary's siblings, per stirpes. If such beneficiary has no then
living siblings, my Trustee shall distribute such beneficiary's trust share to my then living
descendants, pex stirpes. If I have no then living descendants, my Trustee shall distribute such
beneficiary's trust share as provided in the Articles that follow.
Section 5. General Power of Appointment Over Certain Assets
If any separate share or trust established under this Article Eleven shall terminate, or if a
beneficiary's interest therein lapses, upon the death of the beneficiary thereof, my Trustee shall,
anything herein to the contrary notwithstanding, distribute to such appointee or appointees who
are creditors of the estate of such deceased beneficiary, in such proportions and amounts as such
deceased beneficiary shall direct and appoint by such deceased beneficiary's last will and
testament referring specifically to this general power of appointment, those assets composing
such separate share or trust the transfer of which pursuant to the terms hereof, other than this
Section 5, and assuming the nonexercise of any special testamentary power of appointment
elsewhere herein conferred upon such deceased beneficiary, upon such termination would, but
for such general power, cause any tax under Chapter 13 of the Code to be payable. If such
deceased beneficiary shall fail in whole or in part to exercise such general power, then the assets
subject to such general power with respect to which such deceased beneficiary shall have failed
to exercise such general power shall be distributed as otherwise provided in my Trust Agreement.
I certify that I have read the foregoing amendment to my Living Trust, and that it correctly
states the changes I desire to make in my Living Trust. I approve this amendment to my Living
Trust in all panic s, reques my Trustees to execute it.
e W. Waddington, rust °n
/ ~ ~
s%~ ~ -~ ~ .
e W. Waddington, rustee Harold T. Waddington, Tru ee
6
ACHIVOWLEDGEMENT
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF DAUPHIN
The foregoing amendment to the Anne W.
before me on FEB 1 ~ ZOIJ~ ~ by Anne W
Waddington Living Trust was acknowledged
Waddington, as Trustor and Trustee, and by
Harold T. Waddington, as Trustee.
Witness my hand and official seal.
My commission expires:
1 ~ ~~
No ary Public
Nota«.~i s~;~i
Linda L. Fetterhofi, Notary Public
Derry: {inrp.; Iiuuphin County
My Commission cxpir~s Noy:. E, 2903
7
4
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The Second Amendment
to the
Anne W. Waddington Living Trust
On November 20, 2000, I, Anne W. Waddington, signed the Anne W. Waddington Living
Trust, more formally known as:
Anne W. Waddington and Harold T. Waddington, Trustees, or their successors in
trust, under the Anne W. Waddington Living Trust, dated November 20, 2000, and
any amendments thereto
Pursuant to Article Four of my Living Trust, which permits me to amend my Living Trust in
writing at any time, I now wish to amend my Living Trust as follows:
Article Three, Section 4, of my Living Trust is hereby revoked in its entirety and amended
as follows:
Section 4. Designated Successor Trustees
Subject to the provisions of Section 3 of this Article, whenever a Trustee is removed, dies,
resigns, becomes incapacitated, or is otherwise unable or unwilling to serve, the vacant Trustee
position shall be filled as follows:
a. Vacancy in Position of Trustee While I Am Alive and Competent
I may serve as the only Trustee or I may name any number of Trustees to serve
with me. If any of these other Trustees subsequently fails or ceases to serve as a
Trustee for any reason, I may or may not appoint another to fill the vacancy.
b. Incapacity Trustees of ANNE w. WADDINGTON
If ANNE W. WADDINGTON becomes incapacitated while serving as an Initial
Trustee, she shall be replaced by the following Incapacity Trustee(s) to serve in
the priority listed until the list has been exhausted. Unless otherwise specified, if
Co-Incapacity Trustees are serving, the next following named Successor
Incapacity Trustee(s) shall serve only after all of the Co-Incapacity Trustees
initially fail or thereafter cease to act as Trustees:
HAROLD T. WADDINGTON AND THOMAS V. WADDINGTON; THEN
IF HAROLD T. WADDINGTON IS UNABLE OR UNWILLING TO SERVE,
THOMAS V. WADDINGTON AND JOHN F. WADDINGTON AND
RUTH A. PATRICK, OR THE SURVIVOR(S) OF T]3EM; THEN
HERSHEY TRUST COMPANY
c. Death Trustees of ANNE w. WADDINGTON
Upon the death of ANNE W. WADDINGTON, she or her Incapacity Trustee, if either
is then serving as Trustee, shall be replaced by the following Death Trustee(s) to
serve in the priority listed until the list has been exhausted. Unless otherwise
specified, if Co-Death Trustees are serving, the next following named Successor
Death Trustee(s) shall serve only after all of the Co-Death Trustees initially fail or
thereafter cease to act as Trustees:
HAROLD T. WADDINGTON AND THOMAS V. WADDINGTON; THEN
IF HAROLD T. WADDINGTON IS UNABLE OR UNWILLING TO SERVE,
THOMAS V. WADDINGTON AND JOHN F. WADDINGTON AND
RUTH A. PATRICK, OR THE SURVIVOR(S) OF THEM; THEN
HERSHEY TRUST COMPANY
I executed this amendment on ~~~ $ _ aQQ~
I certify that I have read the foregoing amendment to my Living Trust, and that it correctly
states the changes I desire to make in my Living Trust. I approve this amendment to my Living
Trust in all particulars, and request my Trustees to execute it.
Trustor:
~%. r-
Anne W. Waddington
Trustees:
~~d/ • ~~
Anne W. Waddington
Harold T. Waddington
I
ACKNOWLEDGEMENT
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF DAUPHIN .
The foregoing amendment to the Anne W. Waddington Living Trust was acknowledged
before me on ~~Y ~ ~- ~~~ , by Anne W. Waddington as Trustor and Trustee and by
Harold T. Waddington as Trustee.
Witness my hand and official seal.
My commission expires:
No Public
~_.__
M1iotafiat Sea:
Linda L Frti®rtroYr, &~~ota.ry F°ui~tto
DerryTwp., t)aupi7'sn C~u~ni:y
iVty Commrssicr; F'.pires iJ~sv,'3, 2003
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The Third Amendment
to the
Anne W. Waddington Living Trust
On November 20, 2000, I, Anne W. Waddington, signed the Anne W. Waddington Living
Trust, more formally known as:
Anne W. Waddington and Harold T. Waddington, Trustees, or their successors in
trust, under the Anne W. Waddington Living Trust, dated November 20, 2000, and
any amendments thereto.
Pursuant to Article Four of my Living Trust, which permits me to amend my Living Trust
in writing at any time, I now wish to amend my Living Trust as follows:
Article Fifteen, Section I l .a., of my Living Trust is hereby revoked in its entirety and
amended as follows:
Section 11. Survivorship
a. Simultaneous Deaths
For purposes of my Trust Agreement, if my Spouse anal I die under circumstances in
which the order of our deaths cannot be established, husband Trustor shall be deemed to
have died first; wife Trustor shall be deemed to have survived.
If any beneficiary under my Trust Agreement, other than my Spouse, dies under
circumstances in which the order of deaths cannot be established, I shall be deemed to
have survived the beneficiary, and my Trust Agreement shall be construed accordingly.
A11 other articles are hereby ratified and confirmed.
1
l
I executed this amendment on ~ 1
I certify that I have read the foregoing amendment to my Living Trust, and that it correctly
states the changes I desire to make in my Living Trust. I approve this amendment to my Living
Trust in all particulars, and request my Trustees to execute it.
e addington, Tnz t r
t
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e W. addington, Trustee
//~ ,
` ~~~~Z~J
Harold T. Waddington, Trust e
ACKNOWLEDGEMENT
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF DAUPHIN
The foregoing amendment to the Anne W. Waddington Living Trust was aclrnowledged before me
on ~~a~ ~ ~' ~~~" , by Anne W. Waddington, as Trustor and Trustee and by Harold T.
Waddington as Trustee.
Witness my hand and official seal.
My commission expires:
Notary Public ~,
COMMONWEALTFI of Pi=NNSYLVANlA
Notarial Seal
Linda L. Fetter off, Notary Public
Derry Twp., Dauphin County
My Commission Expires Nov. 8, 2007
Member, Pennsylvania Associt~tian C7f Noterlaa
2
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Tllls
LIVING TRUST
prepared for
ANNE W. WADDINGTON
James, Snuth, Durkin & Connelly LLP
134 Sipe Avenue, Hummelstown, PA 17036
Phone: (717) 533-3280 Fax: (717) 533-2795
j sdinfo@j sdlegal.com
Mailing Address:
P.O. Box 650, Hershey, PA 17033
~ Gary L. James
All Rights Reserved
z ~
ANNE W. WADDINGTON LIVING TRUST
Table of Contents
Article One
Article Two
Article Three
Article Four
Article Five
Article Six
Article Seven
Article Eight
Article Nine
Article Ten
Article Eleven
Article Twelve
Article Thirteen
Article Fourteen
Article Fifteen
Trust Creation ......................................................................................... 1-1
The Trust Estate ...................................................................................... 2-1
Appointment of Trustees .......................................................................... 3-1
Trustor's Lifetime Rights ......................................................................... 4-1
Administration at Death of the Trustor ................................................... 5-1
Specific Distributions of Trust Property ................,................................ . 6-1
Division into Survivor's Share and Family Share.. ................................ .. 7-1
The Survivor's Trust ............................................................................... .. 8-1
The Family Trust .................................................................................... . 9-1
Common Pot Trust ................................................................................ 10-1
Division and Distribution of Trust Property .......................................... 11-1
Distribution If No Designated Beneficiaries .......................................... 12-1
Trustee Administration ......................................................................... 13-1
Trustee Powers ...................................................................................... 14-1
General Provisions ................................................................................. 15-1
i
~ Z
ANNE W. WADDINGTON LIVING TRUST
Article One
Trust Creation
Section 1. Parties to My Trust
My Trust Agreement, dated , is made between ArINE W. WADDINGTON, the
Trustor, and the following Initial Trustees:
ANNE W. WADDINGTON
HAROLD T. WADDINGTON
Section 2. Name of My Trust
My Trust may be referred to as the:.
ANNE W. WADDINGTON LIVING TRUST, dated
The formal name of my Trust and the designation to be used for the transfer of title to the name
of my Trust is:
ANNE W. WADDINGTON and HAROLD T. WADDINGTON, Trustees, or their
successors in trust, under the ANNE W. WADDINGTON LIVIr1G TRUST, dated
and any amendments thereto.
Section 3. Revocable Living Trust
My Trust is a revocable trust.
Section 4. Trustor as Trustee
Unless otherwise provided in my Trust Agreement, when I am serving as Trustee under my
Trust, I may conduct business and act on behalf of my Trust without the consent of any other
Trustee.
1-1
Section 5. My Family
Unless specifically provided otherwise in subsequent provisions of my Trust Agreement, all
references to "my children", subject to the exclusion of any child under any subsequent provision
of this Section 5, are to all of the children so identified in this Section 5, but only to those
children and any children born to or adopted by me subsequent to the execution of my Trust
Agreement.
a. Marital Status
I am presently married and the name of my Spouse is HAROLD T WADDINGTON.
b. My Children
The names and birth dates of my children are as follows:
Name
JOHN F. WADDINGTON
DAVID E. PERRY
RUTH A. PATRICK
THOMAS V. WADDINGTON
Birth Date
March 08, 1951
August 7, 1953
October 22, 1957
January 26, 1960
DAVID E. PERRY, the natural child of the Wife Trustor, ANNE W. ~vADDINGTON, is included
in the definition of "my children" for the purposes of this Trust Agreement and regardless
of his adoption by other persons.
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Article Two
The Trust Estate
Section 1. Initial Transfer of Property
I hereby assign, convey, transfer and deliver to my Trustee all property set forth on Schedule
"A", attached hereto, and made part of my Trust Estate. My Trustee acknowledges receipt of all
assets listed on the attached Schedule.
All assets titled in the name of my Trust or in the name of my Trustee, but not listed on Schedule
"A", shall be considered a part of my Trust Estate as if they had 'been set forth on the attached
Schedule.
The Trustor aclrnowledges and understands the nature of the Trustor':; property as community
property, quasi-community property, tenancy in common property or separate property.
Section 2. Additional Transfers to Trust
I, or any other person or entity, may transfer or devise to my Trustee additional assets, real or
personal, and may name my Trustee as the beneficiary of life insurance policies, annuities,
retirement plans or similar contracts. Such assets, policies and proceeds, upon acceptance by my
Trustee, shall be a part of my Trust Estate, subject to all the terms of my Trust Agreement.
Section 3. Character of Trust Assets
All property transferred by me into my Trust shall retain its charac;ter. All such property
transferred, and income thereon less withdrawals thereof, shall be my Tnzst Estate.
Section 4. Acceptance of Trust Property
All property transferred to my Trust, and accepted by my Trustee, shall be held, administered and
distributed according to the terms of my Trust Agreement.
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Article Three
Appointment of Trustees
Section 1. Definition of Trustee
All uses of the word "Trustee" in my Trust Agreement shall be deemed a reference to the person
or entity then serving as Trustee and shall include alternate or Successor Trustees or Co-Trustees
(if multiple trustees are serving), unless the context requires otherwise.
Section ~. icesi~nation of a T i'ustee
Any Trustee may resign at any time without court approval by giving written notice to me if I am
living and competent. If I am not then living and competent, written notice shall be given to my
next Successor Trustee; or if there is no next Successor Trustee, to the beneficiaries then entitled
to receive income or principal distributions under my Trust Agreement or their respective
Personal Representatives, or if any of such beneficiaries then be a minor, to the persons having
the care or custody of any such minor. Such resignation shall be effective upon the appointment
of a Successor Trustee.
Section 3. Removal of a Trustee
Any Trustee may be removed under my Trust Agreement as follows:
a. While I Am Alive and Competent
While I am alive and competent, I may add a Trustee, or remove or replace any
other Trustee appointed under my Trust Agreement at any time without cause.
b. Removal by Others
Upon my death or incapacity, any Trustee may be removed at aaly time for cause
by a majority vote of the beneficiaries then entitled to receive income or principal
distributions under my Trust Agreement, or their Personal Repre~;entatives.
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c. Notice to Removed Trustee
Written notice of removal under my Trust Agreement shall be effective
immediately when signed by the person or persons authorized to make the
removal and delivered to my Trustee personally or three business days after
mailing by certified mail, return receipt requested. The written :notice removing a
Trustee shall identify the Successor Trustee appointed pursuant to the other
provisions of this Article.
d. Transfer of Trust Property
The Trustee so removed shall promptly transfer and deliver to the Successor
Trustee all property of my Trust under the removed Trustees possession and
control.
Section 4. Designated Successor Trustees
Subject to the provisions of Section 3 of this Article, whenever a Trustee is removed, dies,
resigns, becomes incapacitated, or is otherwise unable or unwilling to serve, the vacant Trustee
position shall be filled as follows:
a. Vacancy in Position of Trustee While I Am Alive and Competent
I may serve as the only Trustee or I may name any number of Trustees to serve
with me. If any of these other Trustees subsequently fails or ceases to serve as a
Trustee for any reason, I may or may not appoint another to fill the vacancy.
b. Incapacity Trustees of ANNE W. WADDINGTON
If ANNE W. WADDINGTON becomes incapacitated while serving as an Initial
Trustee, she shall be replaced by the following Incapacity Trustee(s) to serve in
the priority listed until the list has been exhausted. Unless otherwise specified, if
Co-Incapacity Trustees are serving, the next following named Successor
Incapacity Trustee(s) shall serve only after all of the Co-Incapacity Trustees
initially fail or thereafter cease to act as Trustees:
HAROLD T. WADDINGTON; THEN
JOHN F. WADDINGTON AND RUTH A. PATRICK ANI;~
THOMAS V. WADDINGTON, OR
THE SURVNOR(S) OF THEM; THEN
HERSHEY TRUST COMPANY
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c. Death Trustees of ANNE w. WADDINGTON
Upon the death of ANNE W. WADDINGTON, she or her Incapacity Trustee, if either
is then serving as Trustee, shall be replaced by the following Death Trustee(s) to
serve in the priority listed until the list has been exhausted. Unless otherwise
specified, if Co-Death Trustees are serving, the next following named Successor
Death Trustee(s) shall serve only after all of the Co-Death Trustees initially fail or
thereafter cease to-act as Trustees:
HAROLD T. WADDINGTON; THEN
JOHN F. WADDINGTON AND RUTH A. PATRICK ANI>
THOMAS V. WADDINGTON, OR
THE SURVIVOR(S) OF THEM; THEN
HERSHEY TRUST COMPANY
Section 5. No Designated Successor Trustees
If at any time there is no Trustee acting under my Trust Agreement acid there is no person or
institution designated and qualified as a Successor Trustee, a majority of the beneficiaries then
eligible to receive distributions of income or principal under my Trust Agreement or their
Personal Representatives, shall appoint a Successor Trustee. If any trust existing under my Trust
Agreement lacks a Trustee and no successor is appointed pursuant to this Article, the vacancy
shall be filled by a court of competent jurisdiction.
Section 6. Responsibility of Successor Trustees
Other than amending or revoking my Trust, or appointing or removin€; a Trustee, a Successor
Trustee shall have the same rights, powers, duties, discretion and immunities as if named as
Initial Trustee under my Trust Agreement. No Successor Trustee shall be personally liable for
any act, or failure to act, of any predecessor Trustee or shall have any duty to examine the
records of any predecessor Trustee. A Successor Trustee may accept the account rendered and
the property delivered by, or on behalf of, a predecessor Trustee as a full and complete discharge
of the duties of the predecessor Trustee without incumng any responsibility or liability for doing
so.
Section 7. Co-Trustee's Responsibility for the Acts of Otb~er Co-Trustees
No Co-Trustee shall be responsible for the act, omission or default of any other Co-Trustee
without actual knowledge thereof.
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Article Four
Trustor's Lifetime Rights
Section 1. Income and Principal
a. Right to Trust Income and Principal
My Trustee shall pay to me, or apply for my benefit during my li~~fetime, all or part
of the income and principal of my Trust Estate as I may direct.
b. Trustee Liability
Upon any distribution of the income or principal of my Trust Estate authorized or
directed by me, my Trustee shall incur no liability, and shall be under no
obligation or responsibility for such distribution.
Section 2. Trustor's Rights During Incapacity
a. Incapacitated Trustor's Intent to Return Home
Notwithstanding any other provision in my Trust Agreement, as a notification to
any governmental benefits provider, it is conclusively presumed that I intend to
return home.
b. Income and Principal Distributions
During any period of my incapacity, my Trustee shall pay to my Personal
Representative, or apply for my benefit, as much of the net income and principal
of my Trust Estate as my Trustee, in my Trustee's discretion, shall deem necessary
or advisable. Any undistributed net income shall be added to principal.
c. Income and Principal Distribution for the Trustor's Spouse
After making payments authorized under Section 2.b of this Article, during any
period of my incapacity, my Trustee shall pay to, or apply for the benefit of, my
Spouse, as much of my Trust Estate as my Trustee, in my Tn~stee's discretion,
shall deem necessary or advisable, from time to time, for my Spouse's health,
education, maintenance or support, taking into consideration my Spouse's other
income or resources. Any undistributed net income shall be added to principal.
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d. Tax and Government Benefits Planning
Should I become incapacitated, my Trustee shall cooperate in ta;~ and government
benefits planning with my Agent appointed under a durable power of attorney; or,
if none, with any Personal Representative that may be appointed by a court of
competent jurisdiction, but the primary concern of my Trustee; shall be for my
welfare and secondarily for such planning.
Section 3. Right to Amend or Revoke My Trust During I~ife and at Death
a. Power to Revoke and Amend While I Am Living
While I am alive, I may at any time or times amend any provisions of my Trust
Agreement or revoke my Trust in whole or in part.
b. Method to Revoke or Amend During Life
Any amendment or revocation of my Trust Agreement made dw-ing my life shall
be by a written instrument signed by me and delivered to my Trustee.
c. Authorized Power and Method to Amend at Death
If Code .section 401(a)(9) is interpreted to allow the beneficiaries of a trust to
qualify as a "designated beneficiary" if such trust may be so amended at death,
then by a duly probated last will which exercises this power to amend, I may also
amend any provisions of my Trust. In addition, my Spouse may amend any trust
or trust share over which my Spouse has a general non-lapsing power of
appointment over principal. Notwithstanding the preceding, any Retirement
Benefits allocated to any trust or trust share due to my death shhall be held in a
separate share of that trust or a separate subshare of such share, as the case may
be, that shall be irrevocable upon my death. The allocation of Retirement
Benefits to any such irrevocable trust share or subshare, is intended to qualify the
beneficiaries of such trust share or subshare as a "designated beneficiary" under
Code section 401(a)(9).
d. Trustee Consent
Any exercise of a power of amendment substantially affecting the duties, rights
and liabilities of my Trustee shall be effective upon my Trustee ~~nly if agreed to
by my Trustee in writing.
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e. Delivery of Property After Revocation
After any revocation with respect to my Trust, my Trustee shal:~ promptly deliver
the trust property to me.
f. Trustee's Retention of Assets Upon Revocation
In the event of any revocation of all or part of my Trust, my Trustee shall be
entitled to retain sufficient assets to reasonably secure the payment of liabilities
my Trustee has lawfully incurred in administering my Trust unless I indemnify
my Trustee against loss or expense.
Section 4. Exercise of Trustor's Rights and Powers by Others
Any right or power, other than an amendment by will, or any right or power that would constitute
a general power of appointment if held by my Agent, that I may exercise under the terms of my
Trust Agreement, may be exercised for and on my behalf by any Agent who, at the time of the
exercise, is duly appointed and acting for me under a valid and enforceable power of attorney
executed by me. Only if no such Agent is then available, a Personal Representative appointed by
a court of competent jurisdiction may exercise such right or power.
Other than as provided in this Section 4, the powers under my Trust Agreement are personal to
me and may not be exercised by any other person or entity.
Section 5. Property Held as Nominee
For administrative convenience, it is contemplated that certain assets may be added to my Trust
Estate from time to time with the possession and control thereof retained. by or redelivered to me.
Notwithstanding such control or redelivery, such assets shall be assets of my Trust Estate and
held by me as the nominee of my Trustee. During the period such assets are in my possession
they shall be subject to the following terms and conditions:
a. I may receive directly and devote to my own use and. benefit any dividends,
interest, income, or proceeds or distributions from or upon such assets and neither
I nor my Trustee shall have any duty of accounting to the other or to any other
person with regard thereto.
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b. Any sale, exchange or other transfer of such assets by me shall constitute a
withdrawal of such assets from the Trust Estate and my Trustee shall have no
further interest therein or duties with regard thereto. Though not a condition
precedent to any such withdrawal, I agree to notify my Trustee of all such
withdrawals.
c. I shall be responsible for the reporting of the income from such assets to the
appropriate taxing authorities and my Trustee shall have no responsibility for
including such income on any fiduciary returns prepared by my Trustee or for the
preparation of any other government filing with respect thereto unless I duly
notify my Trustee of such income items and a full and adequate accounting
thereof is made and presented to my Trustee.
d. I shall protect and indemnify my Trustee against all losses, liabilities and
expenses which may result directly or indirectly from my use, possession,
management or control of such assets.
e. Upon my death or incapacity, my Trustee shall remain entitled to the possession
thereof and shall continue to have all the rights, powers and duties with respect to
such assets which are granted to my Trustee herein. My Trustee is not responsible
for assets held by me as nominee. However, it is also understood that my Trustee
shall use any reasonable and prudent means to secure possession of any trust
assets of which my Trustee has knowledge. My Trustee shall have no duty,
accountability or responsibility to me or to any other person with respect to any
assets of which my Trustee has no knowledge or of which. my Trustee is unable to
obtain possession and control.
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Article Five
Administration at Death of the Tr~ustor
Section 1. Trustee's Payment of Debts and Taxes
After my death, unless other provisions for payment have been made, my Trustee shall pay all or
any part of the following expenses, debts, claims and taxes from my Trust Estate:
a. Final medical expenses and all funeral costs;
b T aaall~~ enfnrreahle rlaimg avainet me'
..b»..~ b.......,.. ,
c. Reasonable expenses of administration of my Trust, including those attributable to
my probate estate or those attributable to the distribution of any bequest;
d. Any allowances mandated by a court of competent jurisdiction to those dependent
upon me;
e. Any estate, inheritance, succession, generation skipping transfer, or similar taxes
payable by reason of my death; and
f. Any penalties or interest on any of the above expenses, claims, debts or taxes
owed by me or my probate estate.
Section 2. Payment by My Trustee or Personal Representative
My Trustee, in my Trustee's discretion, may make distributions authorized under this Article
either directly to the person or entities to whom payment is owed or to the Personal
Representative of my probate estate. Written statements by my Personal Representative that
such sums are due and payable by my estate shall be sufficient eviden~~ce of their amount and
propriety for the protection of my Trustee. My Trustee shall be under no duty to see to the
application of any such payments made to my Personal Representative.
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Section 3. Tax Elections
If no Personal Representative has been appointed, with regard to the payment of any income tax,
gift tax, estate tax, inheritance tax, Generation Skipping Transfer T~ix or any other tax due
because of my death, my Trustee shall have the right to make any available elections allowed
under the law or to sign and file any tax return. If a Personal Representative has been appointed,
the Personal Representative shall have the foregoing rights and duties.
Section 4. Payment of Death Taxes, Claims and Expenses
a. Payment Out of Trust Property
All death taxes, claims and expenses payable under the provisions of this Article
may be paid by my Trustee out of my Trust Estate except as specifically provided
for elsewhere in my Trust Agreement. Such payments may be aillocated, partly or
wholly, in my Trustee's discretion, to income or principal; but, to income only to
the extent such allocation does not constitute a material limitation upon any trust
portion that would otherwise qualify for the federal estate tax l~2arital Deduction
or decrease any otherwise allowable Charitable Deduction.
b. Exception for Property Passing Outside of My Trust
Notwithstanding Section 4.a of this Article, unless specifically directed otherwise
by another separate provision of my Trust Agreement, all death taxes, claims and
expenses attributable to assets passing outside of my Trust or nny probate estate
shall be assessed against those persons receiving such property; provided,
however, that under no circumstances shall any transfer to any beneficiary that
qualifies for the federal estate tax Marital or Charitable Deduction cause the
property transferred or such beneficiary to bear any such taxes.
Section 5. Apportionment of Expenses, Claims and Taxes
Notwithstanding Section 4.a of this Article, unless specifically directed otherwise by another
separate provision of my Trust Agreement, all expenses, claims and taxes attributable to any
specifically distributed property shall be apportioned to the share of the beneficiaries of such
specific distributions. Any distribution of specific trust property under my Trust Agreement
shall pass subject to all liens, mortgages or encumbrances attributable thereto.
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Section 6. Exception to Apportionment of Death Taxes
Notwithstanding any provision in my Trust Agreement to the contrary, it is my intent, and I
hereby direct, that to the extent practicable no death taxes shall be apportioned to or against any
part of my estate or the trusts or shares created by my Trust Agreement, or any beneficiary
thereof, which qualifies for the federal estate tax Marital Deduction ~~r Charitable Deduction.
Further, notwithstanding any above provisions, Death Taxes chargeablE; among trusts hereunder
that are substantially identical except that one trust is Exempt and the other Trust is Non-Exempt
shall be charged first to the Non-Exempt Trust until exhausted and then to the Exempt Trust.
The preceding sentence shall not apply to the extent that charging and paying such taxes as
provided in such sentence increases the Inclusion Ratio of any Exempt Trust hereunder.
Furthermore, should the payment of expenses, claims and taxes from any Qualified Retirement
Plan or Individual Retirement Account ("IRA") assets which comprise my Trust Estate cause my
Tnict to be disq»alifierl as a "(~iiali_fi_ed Repe_fi_~.iary" Tnlst~ it is my intent and I hereby direr.t~
that to the extent practicable, no expenses, claims and taxes be paid from such Qualified
Retirement Plan or IItA assets.
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Article Six
Specific Distributions of Trust Property
Section 1. Distributions Under Article Six
Except for the specific distributions directed in the following Sections of this Article Six, all
distributions of trust property shall be made in accordance with the Articles that follow.
Section 2. Income in Respect of a Decedent ("IRD")
After my death, my Trustee shall distribute a fraction of all items of IR.D in my Trust Estate to
the Survivor's Trust. Any IRD not distributed to the Survivor's Trust shall be distributed to the
Family Trust to the extent such allocation will not exceed my Unused Applicable Credit
Equivalent. The fraction to be distributed to the Survivor's Trust shall bc; determined by dividing
my Spouse's Unused Applicable Credit Equivalent, reduced by the balance of my Spouse's then
Taxable Estate, before any distributions pursuant to Article Seven or otherwise have been made
to the Survivor's Trust from property included my Gross Estate, by the ~ralue of all items of IRD
in my Trust Estate or otherwise received by my Trustee due to my death. Other than pursuant to
the terms of Article Twelve, if any IlZD consists of any benefits subject to the provisions of Code
Section 401(a)(9), no beneficiary who is not an individual may receive airy such benefits.
Section 3. Estate Planning Letter or Memorandum
To the extent permitted by state law and not necessary to fully utilize my Unused Applicable
Credit Equivalent, my Trustee shall distribute personal or household iterns from my Trust Estate
to such persons as I may direct by a written instrument delivered to my Trustee.
Section 4. Specific Distribution Not a Part of My Trust Estate
If the property making up any specific distribution set forth in this Article is not part of my Trust
Estate at the time such specific distribution is directed to be made and vc~ill not become a part of
my Trust Estate within a reasonable time, my Trustee shall disregard that specific distribution.
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Article Seven
Division into Survivor's Share and Fa>~r~ily Share
Section 1. Division of My Trust Estate
Upon my death, my Trustee shall allocate and distribute my remaining; Trust Estate, including
any property that becomes distributable or payable to my Trustee at my death, into two separate
shares to be identified as the Survivor's Share and the Family Share.
a. Property Transferred to the Survivor's Share
The Survivor's Share shall consist of that amount of assets of my Trust Estate
equal in value to the amount that when added to my Spouse's then Taxable Estate,
after any allocation pursuant to Article Six of my Trust Agreement, equals my
Spouse's Unused Applicable Credit Equivalent.
b. Survivor's Share to Be Administered as Survivor's Triust
The Survivor's Share shall be held, administered and distributed. according to the
provisions of the Survivor's Trust as set forth in Article Ei,,ht of my Trust
Agreement.
c. Property Transferred to the Family Share
The Family Share shall consist of all assets of my Trust Estate :not distributed to
the Survivor's Share to the extent such allocation will not cause the Family Share
to hold assets in an amount which exceeds my Unused Applicable Credit
Equivalent. Any such excess shall be distributed to the Survivor's Share.
d. Family Share to Be Administered as Family Trust
The Family Share shall be held, administered and distributed according to the
provisions of the Family Trust as set forth in Article Nine of my 'Crust Agreement.
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Section 2. Allocation and Valuation of Assets
In allocating assets between the Survivor's Share and the Family Share, my Trustee shall allocate
the trust assets between the Survivor's Share and the Family Share in cash or in kind, or partly in
each, on a pro rata or non pro rata basis, and in undivided interests or not; subject, however, to
the following:
a. Qualification for Marital Deduction
My Trustee shall allocate to the Survivor's Share only those assets that qualify for
the Marital Deduction.
b. Valuations of Allocations in Kind
Assets allocated in kind shall be valued on the basis of their values as finally
determined for federal estate tax purposes; provided, however, that my Trustee
shall act impartially, consistent with equitable principles requiring impartiality
among beneficiaries, in allocating assets so that any distribution of assets shall be
made of assets, including cash, fairly representative of appreciation or
depreciation in the value of all property thus available for distribution.
c. Income
The Survivor's Share and the Family Share shall be entitle~3 to a currently
distributable pro rata share of the income earned on my Trust Estate and my
probate estate from the date of my death, including a share of income earned on
assets used to discharge liabilities.
d. Foreign Death Tax Credit
My Trustee shall not allocate assets that qualify for the Foreign Death Tax Credit
to the Survivor's Share unless all other assets or interests available for allocation
have been so allocated.
e. Insurance Policies
Notwithstanding any other provisions to the contrary, as to any policy of
insurance on the life of my Spouse that is allocated to the F~unily Share, my
Spouse shall not have the right, either individually or in a fiduciary capacity, to
hold or control any incident of ownership in, or exercise any powc;r over, any such
policy or the cash value therein or financial benefit derived therefi•om; but, may
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direct that an Independent Trustee to exercise such powers be appointed pursuant
to the Trustee succession provisions of Article Three that would apply as if no
Trustee were then serving, provided, however, that my Spouse inay not otherwise
participate in the appointment process.
f. Priority
My Trustee shall allocate all assets that are not properly characterized as Income
in Respect of a Decedent ("IRD") in accordance with the provisions of this Article
Seven. IRD assets shall be allocated and distributed under the provisions of
Article Six. If no specific allocation of IRD is directed by Article Six, then IRD
also shall be allocated under this Article Seven.
Section 3. Intention That Survivor's Share Qualify for NTarital Deduction
I intend that the Survivor's Share qualify for the federal estate tax Marital Deduction and my
Trust Agreement shall be construed accordingly. All other provisions of my Trust Agreement
shall be subordinate to that intent. If the granting of any right, power, privilege, authority or
immunity to my Trustee or another person or the imposition of any duty upon my Trustee or
another person by any provision of my Trust Agreement would disqualify any share or interest of
my Spouse from qualifying for the federal estate tax Marital Deduction provided by Section 2056
of the Code, such provision shall be ineffective if and to the extent that the same, if effective,
would so disqualify such share or interest. Notwithstanding any other provision in my Trust
Agreement to the contrary, my Spouse at any time shall have the right to direct my Trustee, in
writing, to convert to reasonably productive property, any underproduct:ive trust property held in
the Survivor's Trust, or in any Trust or Trust share as to which an election is made to qualify all
or part thereof for the Marital Deduction under Section 2056(b)(7) of the Code.
Section 4. Disclaimer of Property
Any power or any interest in property or portion thereof that is disclaimed by my Spouse shall be
held, administered or distributed according to the following terms:
a. Property Disclaimed
My Spouse may disclaim any power or any interest in any properly held in trust or
otherwise for, or to be distributed to or for the benefit of, my Spouse under my
Trust Agreement.
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b. Time to Disclaim
My Spouse may disclaim within the time limits and under the conditions
permitted by the laws regulating disclaimers.
c. Delivery of Disclaimer to My Trustee
A disclaimer by my Spouse maybe exercised by the delivery to my Trustee of an
irrevocable and unconditional refusal to accept any power or a~ly interest in any
property passing to my Spouse or the Survivor's Share.
d. Disclaimer of Survivor's Share
If my Spouse exercises a disclaimer with respect to any interest in any property
set aside as part of the Survivor's Snare, any such disciaimed interest shaii be
added to the Family Share. Notwithstanding any other provisions of my Trust
Agreement to the contrary, any such disclaimed interest and income thereon shall
not be subject to any power of appointment held by my Spouse other than a power
of appointment limited by an ascertainable standard subject to Health, education,
maintenance or support.
e. Disclaimer of Family Share
If my Spouse exercises a disclaimer with respect to any interest in any property
set aside as part of the Family Share, such disclaimed interest shall be distributed
under the relevant terms of the Family Trust.
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Article Eight
Survivor's Trust
Section 1. Rights of Spouse in the Survivor's Trust
My Trustee shall hold, administer and distribute the assets of the Survivor's Trust as follows:
a. Payment of Income
My Trustee shall pay to, or apply for the benefit of, my Spouse, so long as my
Spouse lives, the entire net income of the Survivor's Trust in monthly or other
convenient installments agreed upon by my Spouse and my Tn~stee, but not less
often than annually.
If my Trustee is entitled to payments from any Retirement Account, my Trustee
shall allocate to income from payments received in any calendar year an amount
equal to the income earned by the Account in such year, and an.y excess shall be
allocated to principal, and if the payments in such year are less than the amount
equal to the income earned by the Account in such year, my Spouse shall have the
continuing right to require my Trustee to withdraw from the Account and pay to
my Spouse, as income, an additional amount so that my Spouse can be paid an
amount equal to such income; and to require my Trustee to satisfy any remaining
deficiency from principal or make other arrangements to ensure ghat the Survivor's
Trust qualifies for the Marital Deduction.
b. Discretionary Payment of Principal
At any time or times during my Spouse's life, my Trustee shall pay to, or apply for
the benefit of, my Spouse so much of the principal of the Survivor's Trust as my
Trustee deems proper for my Spouse's comfort, welfare, anti happiness. In
exercising discretion, my Trustee shall give consideration to all ether income and
resources then known to be available to my Spouse for use for these purposes.
c. Right of Surviving Spouse to Withdraw Principal
My Trustee shall pay to my Spouse as much of the principal of the Survivor's
Trust as my Spouse may from time to time demand in a signed writing delivered
to my Trustee.
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d. General Power of Appointment
Subject to any payments required under Section 3 of this Article, upon the death
of my Spouse, my Trustee shall distribute all of the Trust Estate of the Survivor's
Trust, including the trust principal and accrued and undistribute;d income, to any
person or entity and upon any trust terms and conditions, or to or in favor of the
estate of my Spouse as my Spouse may direct by my Spouse's last will. No
exercise of this power of appointment shall be effective unless it refers to my
Trust Agreement and expressly indicates an intention to exercise this power of
appointment. My Trustee may rely upon any instrument that m,;~ Trustee in good
faith believes to be the last will of my Spouse in carrying out the terms of this
power of appointment and shall not be liable for any good faith act in reliance
upon that will even if for any reason it is later determined to be invalid with
respect to its purported exercise of this power of appointment. If my Trustee
receives no notice, within six (6} months after the death of my Spouse, of the
existence of a will of my Spouse that exercises this power of appointment, my
Trustee may distribute the Trust Estate of the Survivor's Tru:~t as though this
power of appointment had not been exercised and shall be conclusively presumed
to have acted in good faith even if such a valid will is thereafter discovered.
Section 2. Termination Upon the Death of my Spouse
The Survivor's Trust shall terminate upon the death of my Spouse. My Trustee shall then hold
and administer the balance of the Survivor's Trust as follows:
a. Surviving Spouse's Debts and Taxes
My Trustee may pay all of my Spouse's following expenses, debts, claims and
taxes becoming due or payable by reason of my Spouse's death and equitably
apportioned to the Survivor's Trust:
1. Final medical expenses and all funeral costs;
2. Legally enforceable claims against the Survivor's Trust or
my Spouse's probate estate;
3. Reasonable expenses of administration of the :survivor's
Trust and my Spouse's probate estate, including those
attributable to the distribution of any bequest;
4. Any allowances mandated by a court of competent
jurisdiction to those dependent upon my Spouse;
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5. Any estate, inheritance, succession, death or similar taxes
payable by reason of the death of my Spouse; and
6. Any penalties or interest on any of the above expenses,
claims, debts or taxes owed by my Spouse or m~,~ Spouse's
estate.
Section 3. Administration of Remainder of Survivor's Trust
After making all payments authorized in the preceding provisions of this Article, my Trustee
shall hold and administer the Trust Estate of the Survivor's Trust in accordance with the Articles
that follow.
Section 4. Payment by My Trustee or Personal Representative
My Trustee, in my Trustee's discretion, may make distributions authorized under this Article
either directly to the person or entities to whom payment is ov~~ed or to the Personal
Representative of my Spouse's probate estate. Written statements b:y my Spouse's Personal
Representative that such sums are due and payable by the estate shall lie sufficient evidence of
their amount and propriety for the protection of my Trustee. My Trustee shall be under no duty
to see to the application of any such payments made to my Spouse's Personal Representative.
Section 5. Tax Elections
With regard to the payment of any income tax, gift tax, estate tax, inheritance tax, generation
skipping tax or any other tax required because of the death of my Spouse, if my Spouse has no
Personal Representative and has so authorized my Trustee, my Trustee shall have the right to
make any available elections allowed under the law and shall be authorized to sign and file any
tax return. If my Spouse has a Personal Representative, the Personal Representative shall have
the foregoing rights and duties. If my Spouse has predeceased me, ]: authorize my Spouse's
Trustee, if any, to act with respect to tax elections if I have no Personal Representative.
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Section 6. Generation Skipping Trust
a. Creation of GST Shares One and Two
Notwithstanding the preceding provisions of this Article, if the value of my
Spouse's then taxable estate (inclusive of the Survivor's Share) exceeds my
Spouse's Unused Generation Skipping Tax Exemption Equivalent, the Survivor's
Trust shall be segregated into separate shares identified as GST Share One and
GST Share Two.
My Spouse, however, is hereby granted the .continuing power to direct my
Trustee, in a writing delivered to my Trustee at any time, to disregard the asset
allocation provisions (and GST Share creation provisions) of this Section 6 as to
ar~y, or all, or any part of any interest :n a^;' assets, of my Trast .Estate th~+ ~vn,~l,~
uu~ r vuiu
be affected by such allocation and to administer such assets in accordance with
the other Sections of this Article Eight. My Spouse is encouraged, but not
directed, to disclaim such power, in whole or in part, or as to :interests in some
assets but not others (and is specifically hereby authorized to do so), in order to
obtain any available Generation Skipping Transfer Tax exclusi~~n benefits as to
such assets of my Trust Estate. Nevertheless, if my Spouse determines that
unrestricted access to all or any part of my Trust Estate, or interests in specific
assets thereof, is preferable to exclusion from the Generation Skipping Transfer
Tax, then my Spouse may retain so much of this power as desired by not
exercising a disclaimer to the extent selected by my Spouse.
b. Allocation to GST Share One and Share Two
My Trustee shall allocate to GST Share One that fraction of the Survivor's Trust
determined by dividing my Unused Generation Skipping Tax Exemption
Equivalent by the value of the assets of the Survivor's Trust. Any assets not
allocated to GST Share One shall be allocated to GST Share Two..
c. Administration of GST Share One
My Trustee shall hold, administer and distribute the assets of G:iT Share One as
follows:
1. Payment of Income
My Trustee shall pay to, or apply for the benefit of, my Spouse, so
long as my Spouse lives, the entire net income of GST Share One in
monthly or other convenient installments agreed upon by my Spouse
and my Trustee, but not less often than annually.
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If my Trustee is entitled to payments from any Retirement Account,
my Trustee shall allocate to income from payments received in any
calendar year an amount equal to the income earned by th.e Account
in such year, and any excess shall be allocated to principal, and if the
payments in such year are less than the amount equal to the income
earned by the Account in such year, my Spouse shall. have the
continuing right to require my Trustee to withdraw from the Account
and pay to my Spouse, as income, an additional amount so that my
Spouse can be paid an amount equal to such income; and to require
my Trustee to satisfy any remaining deficiency from principal or
make other arrangements to ensure that the Survivor's Tru:>t qualifies
for the Marital Deduction.
2. General Power of Appointment Over Undistributed Net
Income
Upon the death of my Spouse, my Trustee shall distribute; all of the
accrued but undistributed net income of GST Share O:ne to any
person or entity and upon any trust terms and conditions, or to, or in
favor of, the estate of my Spouse, as my Spouse may direct by my
Spouse's last will. No exercise of this power of appointment shall be
effective unless it refers to my Trust Agreement and expressly
indicates an intention to exercise this power of appointment. My
Trustee may rely upon any instrument that my Trustee in ,good faith
believes to be the last will of my Spouse in carrying out the terms of
this power of appointment and shall not be liable for any ;;ood-faith
act in reliance upon that will, even if for any reason it is later
determined to be invalid with respect to its purported exercise of this
power of appointment. If my Trustee receives no notice, within six
(6) months after the death of my Spouse, of the existence of a will of
my Spouse that exercises this power of appointment, my Trustee
may distribute the accrued but undistributed net income as though
this power of appointment had not been exercised and. shall be
conclusively presumed to have acted in good faith even if such a
valid will is thereafter discovered.
3. Discretionary Payment of Principal
At any time or times during my Spouse's life, my Trustee shall pay
to, or apply for the benefit of, my Spouse so much of the principal of
GST Share One as my Trustee deems proper for my Spouse;'s health,
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education, maintenance or support. In exercising discretion, my
Trustee shall give consideration to all other income and resources
then known to be available to my Spouse for use for these~~urposes.
4. Limitation on Discretionary Payment of Principal by
Trustee
Notwithstanding the provisions of Section 6.c.3 of this Article, I
recommend, but do not require, that my Trustee shall first exhaust
the principal from GST Share Two before making discretionary
payments of principal from GST Share One.
5. Limited Power of Appointment
Fty a last will, my Spouse shalt have the limited testament;sry power
to appoint to, or for the benefit of, my descendants some oi• all of the
principal, including unappointed income of GST Share (one, as it
exists at the date of death of my Spouse after payment of expenses,
debts, claims and taxes pursuant to Section 6.c.7 of this Article. My
Spouse may appoint trust assets under this limited testamentary
power among my descendants in equal or unequal amounts, either
directly or in trust, as my Spouse directs.
This limited testamentary power of appointment shall not be
exercised in favor of my Spouse's estate, the creditors of m;y Spouse,
the creditors of my Spouse's estate, or in any way that would result
in any economic benefit to my Spouse. If my Trustee receives no
notice, within six (6) months after the death of my Spouse, of the
existence of a will of my Spouse that exercises this ~~ower of
appointment, my Trustee may distribute the accrued but
undistributed net income as though this power of appointment had
not been exercised and shall be conclusively presumed to have acted
in good faith even if such a valid will is thereafter discovered.
6. Termination Upon the Death of my Spouse
GST Share One shall terminate upon the death of my Spouse. My
Trustee shall then hold and administer the balance of G:iT Share
One in accordance with the following provisions of this Section 6.c.
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7. My Spouse's Debts and Taxes
Taking into consideration any waiver pursuant to section 2207A of
the Code in the last will of my Spouse, my Trustee may pay all of
my Spouse's following expenses, debts, claims and taxes becoming
due or payable by reason of my Spouse's death and. equitably
apportioned to the Survivor's Trust; but from GST Share One only to
the extent not paid from GST Share Two:
(a) Final medical expenses and all funeral costs;
(b) Legally enforceable claims against the
Survivor's Trust or my Spouse's probate
estate;
(c) Reasonable expenses of administration of the
Survivor's trust and my Spouse's probate
estate, including those attributable to the
distribution of any bequest;
(d) Any allowances mandated by a court of
competent jurisdiction to those dependent
upon my Spouse;
(e) Any estate, inheritance, succession, death or
similar taxes payable by reason of the de;~th
of my Spouse; and
(f) Any penalties or interest on any of the above
expenses, claims, debts or taxes owed.
S. Payment by My Trustee or Personal Representative
My Trustee, in my Trustee's discretion, may make distributions
authorized under this Section either directly to the person or entities
to whom payment is owed, or to the Personal Representative of my
Spouse's probate estate. Written statements by my Spouse's Personal
Representative that such sums are due and payable by the estate shall
be sufficient evidence of their amount and propriety for the
protection of my Trustee. My Trustee shall be under no duty to see
to the application of any such payments made to my Spouse's
Personal Representative.
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9. Tax Elections
With regard to the payment of any income tax, gift tax, estate tax,
inheritance tax, generation skipping tax or any other ta.x required
because of the death of my Spouse, if my Spouse has no Personal
Representative and has authorized my Trustee to so act, my Trustee
shall have the right to make any available elections allowed under
the law and shall be authorized to sign and file any tax return. If my
Spouse has a Personal Representative, the Personal Representative
shall have the foregoing rights and duties. If my Spouse predeceased
me, I authorize my Spouse's Trustee, if any, to act with respect to tax
elections if I have no Personal Representative.
10. Administration of Remainder of GST Share One
After making all payments authorized above in this Article Eight,
my Trustee shall hold and administer GST Share One as provided in
the Articles that follow.
d. Administration of GST Share Two
My Trustee shall hold, administer and distribute the assets of GST Share Two
pursuant to the terms of Sections 1 through 6, inclusively, of this Article, and after
making all payments authorized in said Sections, my Trustee shall hold and
administer GST Share Two as provided in the Articles that follov~~.
8-8
Article Nine
Family Trust
Section 1. Rights of My Spouse in the Family Trust
My Trustee shall hold, administer and distribute the assets of the Family Trust as follows:
a. Payment of Income
My Trustee shall pay to, or apply for the benefit of, my Spouse, so long as my
Spouse lives, the entire net income of the Family Trust in monthly or other
convenient installments as agreed upon by my Spouse and my Trustee, but not
less often than annually.
b. Discretionary Payment of Principal
At any time or times during my Spouse's life, my Trustee shall pay to, or apply for
the benefit of, my Spouse, so much of the principal of the Family Trust as my
Trustee, in my Trustee's discretion, deems proper for my Spouse's health,
education, maintenance or support.
c. Guidelines for Trustee's Discretion
In exercising discretion, my Trustee shall give consideration to all other income
and resources then known to be available to my Spouse. In exercising discretion,
my Trustee may, but is not required to, consider any differences in income tax
rates as to the Family Trust and permissible distributees of principal. My Trustee
shall accumulate and add to principal any net income not distributed.
d. Limitation on Discretionary Payment of Principal by Trustee
I recommend, but do not require, that my Trustee shall first exhaust the principal
from the Survivor's Trust before making discretionary payment: of principal to
my Spouse from the Family Trust.
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Section 2. Termination of the Family Trust
On the death of my Spouse, the Family Trust shall terminate. All unappointed and undistributed
trust assets, including any accrued and undistributed net income, shall be held, administered and
distributed pursuant to the Articles that follow.
9-2
Article Ten
Common Pot Trust
Section 1. Creation of the Common Pot Trust
At the death of the survivor of me and my Spouse, my Trustee shall not create a Common Pot
Trust. All of my Trust Estate that has not been distributed under prior Articles of my Trust
Agreement shall be held, administered, divided and distributed according; to the provisions of the
Articles that follow.
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Article Eleven
Division and Distribution of Trust Property
Section 1. Division of Trust Property Into Shares
While, to the extent practical, maintaining any previously established Generation Skipping
Transfer Tax ratios relative to trust property, my Trustee shall divide, into separate shares, all of
my Trust Estate not previously distributed under the preceding Articles of my Trust Agreement
(and for purposes of determining such division and subsequent disl;ributions shall take into
account the exclusion of any descendant as maybe directed in Article One) as follows:
Beneficiai-~Name bare
JOHN F. WADDINGTON 25°~a
RUTH A. PATRICK 25%
THOMAS V. WADDINGTON 25%
DAVID E. PERRY 25%
The trust shares shall be held, administered and distributed as follows:
a. Distribution of Trust Share for JOHN F. WADDINGTON
The trust share set aside for JOHN F. wADDnvGTON shall be held, administered and
distributed as follows:
1. Distributions of Net Income
My Trustee shall immediately pay to, or apply for the benefit of,
such beneficiary, all net income from such beneficiary's gust share,
free of trust.
2. Distributions of Principal
My Trustee, in my Trustee's discretion, shall pay to, or apply for the
benefit of, such beneficiary, so much of the principal from such
beneficiary°s trust share as my Trustee deems advisable for such
beneficiary's health, education, maintenance or support.
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At the death of the second to die of my spouse and me, my Trustee
shall distribute 1/2 of the balance of such beneficiary's trust share to
such beneficiary, free of trust.
Five years of the death of the second to die of my spouse acid me, my
Trustee shall distribute the balance of such beneficiary's trust share
to such beneficiary, free of trust.
3. Distribution on Death of Beneficiary
If such beneficiary should die prior to the time that a distribution is
directed to be made, such beneficiary's interest in such trust share
shall lapse and my Trustee shall distribute the balance oi' the trust
share to such beneficiary's then living descendants, per stirpes.
If such beneficiary has no then living descendants, my Truistee shall
distribute such beneficiary's trust share to my them living
descendants, per stirpes.
If I have no then living descendants, my Trustee shall distribute the
balance of the trust share as provided in the Articles that follow.
b. Distribution of Trust Share for RUTH A. PATRICK
The trust share set aside for RUTx A. PaTtuCx shall be held, <<dministered and
distributed as follows:
1. Distributions of Net Income
My Trustee shall immediately pay to, or apply for the benefit of,
such beneficiary, all net income from such beneficiary's tnzst share,
free of trust.
2. Distributions of Principal
My Trustee, in my Trustee's discretion, shall pay to, or apply for the
benefit of, such beneficiary, so much of the principal from such
beneficiary's trust share as my Trustee deems advisable for such
beneficiary's health, education, maintenance or support.
At the death of the second to die of my spouse and me, m,~ Trustee
shall distribute 1/2 of the balance of such beneficiary's trust share to
such beneficiary, free of trust.
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Five years of the death of the second to die of my spouse and me, my
Trustee shall distribute the balance of such beneficiary's trust share
to such beneficiary, free of trust.
3. Distribution on Death of Beneficiary
If such beneficiary should die prior to the time that a dislxibution is
directed to be made, such beneficiary's interest in such trust share
shall lapse and my Trustee shall distribute the balance of the trust
share to such beneficiary's then living descendants, per st:irpes share
to such beneficiary's then living descendants, per stirpes.
If such beneficiary has no then living descendants, my Trustee shall
distribute such beneficiary's trust share to my then living
descendants, per siirpes.
If I have no then living descendants, my Trustee shall distribute the
balance of the trust share as provided in the Articles that follow.
c. Distribution of Trust Share for THOMAS v. WADDING7'ON
The trust share set aside for TxOMAS v. WADDINGTON shall be held, administered
and distributed as follows:
1. Distributions of Net Income
My Trustee shall immediately pay to, or apply for the benefit of,
such beneficiary, all net income from such beneficiary's trust share,
free of trust.
2. Distributions of Principal
My Trustee, in my Trustee's discretion, shall pay to, or apply for the
benefit of, such beneficiary, so much of the principal i'rom such
beneficiary's trust share as my Trustee deems advisable: for such
beneficiary's health, education, maintenance or support.
At the death of the second to die of my spouse and me, rrry Trustee
shall distribute 1/2 of the balance of such beneficiary's trust share to
such beneficiary, free of trust.
Five years of the death of the second to die of my spouse acid me, my
Trustee shall distribute the balance of such beneficiary's trust share
to such beneficiary, free of trust.
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3. Distribution on Death of Beneficiary
If such beneficiary should die prior to the time that a distribution is
directed to be made, such beneficiary's interest in such trust share
shall lapse and my Trustee shall distribute the balance of the trust
share to such beneficiary's then living descendants, per stirpes share
to such beneficiary's then living descendants, per stirpes..
If such beneficiary has no then living descendants, my Tnistee shall
distribute such beneficiary's trust share to my then living
descendants, per stirpes.
If I have no then living descendants, my Trustee shall distribute the
Ual[LL1Ce of llle ll uJl Jllcu c aS pr O Jiu~.u iii l.il~. cu ~i~.i~.o ~uu~ iv .io vv'.
d. Distribution of Trust Share for DAVID E. PERRY
The trust share set aside for DAVID E. PERRY shall be held, ~~dministered and
distributed as follows:
1. Distributions of Net Income
My Trustee shall immediately pay to, or apply for the benefit of,
such beneficiary, all net income from such beneficiary's trust share,
free of trust.
2. Distributions of Principal
My Trustee, in my Trustee's discretion, shall pay to, or apply for the
benefit of, such beneficiary, so much of the principal fi•om such
beneficiary's trust share as my Trustee deems advisable for such
beneficiary's health, education, maintenance or support.
At the death of the second to die of my spouse and me, m;y Trustee
shall distribute 1/2 of the balance of such beneficiary's trust share to
such beneficiary, free of trust.
Five years of the death of the second to die of my spouse and me, my
Trustee shall distribute the balance of such beneficiary's trust share
to such beneficiary, free of trust.
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3. Distribution on Death of Beneficiary
If such beneficiary should die prior to the time that a distribution is
directed to be made, such beneficiary's interest in such trust share
shall lapse and my Trustee shall distribute the balance of the trust
share to such beneficiary's then living descendants, per s~tirpes share
to such beneficiary's then living descendants, per stirpes.
If such beneficiary has no then living descendants, my Trustee shall
distribute such beneficiary's trust share to my then living
descendants, per stirpes.
If I have no then living descendants, my Trustee shall distribute the
balance of the trust share as provided in the Articles that follow.
Section 2. Distributions to Underage or Incapacitated B~eneBciaries
Notwithstanding any provision to the contrary in this Article Eleven acid subject to Section 2 of
Article Fifteen, if any beneficiary otherwise entitled to receive a distribution of trust property is
under the age of 40 years or is incapacitated, as defined in Article Fifteen, my Trustee shall retain
and administer such beneficiary's trust share for such beneficiary's benefit pursuant to the
following provisions of this Article Eleven:
a. Incapacitated Beneficiary
If such beneficiary's trust share is being held under this Section 2 due to such
beneficiary's incapacity (as defined in Article Fifteen) then, only during the term
of such incapacity, such beneficiary's trust share shall be admirstered according
to the Special Needs Provisions of Article Fifteen. Upon the beneficiary's
regaining capacity (as determined under Article Fifteen) the following provisions
of this Article Eleven shall apply.
b. Underage Beneficiary
If such beneficiary's trust share is being held under this Section 2 due to such
beneficiary's being under the age of 40, such beneficiary's trust share shall be
administered as follows:
11-5
1. My Trustee's Discretion
My Trustee shall pay to, or apply for the benefit of, such b~;neficiary,
so much of the net income and principal of such beneficiary's trust
share as my Trustee, in my Trustee's discretion, deems proper
considering all other resources then known to be available to such
beneficiary.
Z. Payments Made to Beneficiary or Personal
Representative
My Trustee is authorized to make payments under this Section 2.b
directly to the beneficiary, to the beneficiary's Personal
Representl1ative or to an/~y other person my Trustee may deem proper
to be uselnl for the benefit of the bell°vfiviar,'.
3. Trustee's Decisions Are Final
All decisions by my Trustee as to whom my Truste;e makes
payments, the purposes for which payments are made and the
amounts to be paid out of any trust share are within my Trustee's
discretion.
4. Undistributed Net Income
All undistributed net income shall be accumulated and added to the
principal of the trust share.
Section 3. Termination and Distribution as to Underage or Incapacitated
Beaeficiary
Unless distributions from a trust share are withheld pursuant to Section "l of Article Fifteen, my
Trustee shall distribute the trust share to the respective beneficiary of the share being held under
Section 2 of this Article Eleven on the latest to occur of (i) the date upon which such beneficiary
reaches the age of 25 years; (ii) one-fourth (1/4) of the trust share when .such beneficiary attains
the age of 25 years, one-half (1/2) of the balance of the trust share when such beneficiary attains
the age of 30 years, and the balances of the trust share when such beneficiary attains the age of
40 years; or (iii) when such beneficiary is no longer incapacitated, as detE;rmined pursuant to the
provisions of Article Fifteen.
11-6
Section 4. Death of Incapacitated or Underage Beneficiary
Subject to the provisions of preceding Sections of this Article Eleven, if any beneficiary whose
trust share is being held in trust under such Sections dies before the complete distribution of such
beneficiary's trust share, the beneficiary's interest in such trust share shall lapse and my Trustee
shall distribute such beneficiary's trust share to such beneficiary's there living descendants, per
stirpes; or, if none, to such beneficiary's siblings, per stirpes. If such beneficiary has no then
living siblings, my Trustee shall distribute such beneficiary's trust ;hare to my then living
descendants, per stirpes. If I have no then living descendants, my Trustee shall distribute such
beneficiary's trust share as provided in the Articles that follow.
Section 5. General Power of Appointment Over Certain Assets
If any separate share or trust established under ibis Article Eleven shaii terminate, or if a
beneficiary's interest therein lapses, upon the death of the beneficiary thereof, my Trustee shall,
anything herein to the contrary notwithstanding, distribute to such appointee or appointees who
are creditors of the estate of such deceased beneficiary, in such proportions and amounts as such
deceased beneficiary shall direct and appoint by such deceased be~leficiary's last will and
testament referring specifically to this general power of appointment, those assets composing
such separate share or trust the transfer of which pursuant to the terms hereof, other than this
Section 5, and assuming the nonexercise of any special testamentar}~ power of appointment
elsewhere herein conferred upon such deceased beneficiary, upon such termination would, but
for such general power, cause any tax under Chapter 13 of the Code to be payable. If such
deceased beneficiary shall fail in whole or in part to exercise such general power, then the assets
subject to such general power with respect to which such deceased beneficiary shall have failed
to exercise such general power shall be distributed as otherwise provided in my Trust
Agreement.
11-7
Article Twelve
Distribution if No Designated Beneficiaries
Section 1. Remainder by Intestate Succession
If at any time there is no beneficiary entitled to receive all or any part ~~f my Trust Estate under
the preceding Articles, all of the remaining portion of my Trust Estate shall then be distributed to
the GREATER HARRISBURG FOUNDATION to be distributed, in equal shares, for the benefit of the
following:
GAUDENZIA, INC. CENTRAL REGION
BETHESDA MISSION
AMERICAN RED CROSS - PA CAPITAL REGION CHAP'T'ER
SALVATION ARMY
CAMP HILL PRESBYTERIAN CHURCH FOUNDATI01v
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Article Thirteen
Trustee Administration
Section 1. Required Vote for Co-Trustees
a. Trustor Serving as Co-Trustee
Unless otherwise provided in my Trust Agreement, if I am serving as a Co-
Trustee under my Trust Agreement, I may make decisions and bind my Trust in
the exercise of all powers and discretions granted to me as Trustee without the
consent of any other Trustee.
b. Unanimous Vote for Two Trustees
Other than when I am serving as Co-Trustee, if only two Trustees are serving,
they shall act unanimously in the exercise of all powers and discretions granted to
them under my Trust Agreement.
c. Majority Vote for More Than Two Trustees
Other than when I am serving as a Co-Trustee, if more than two Trustees are
serving under my Trust Agreement, they shall act by majority vote and any
exercise of a power or discretion by a majority of the Trustees shall have the same
effect as an exercise by all of them.
d. Court Order Resolves Disputes
Other than when I am serving as a Trustee, if the Trustees are riot able to reach
agreement on any decision as set forth in this Section 1, they shall petition a court
of competent jurisdiction for instructions and shall take no action on the disputed
matter until a court order deciding the issue has been rendered.
Section 2. Power to Delegate
Notwithstanding any other provision of my Trust Agreement, any one or more of the
Co-Trustees serving under my Trust Agreement may from time to time delegate to another
Co-Trustee or Co-Trustees routine acts of trust administration.
13-1
Section 3. No Bond Required
No Trustee specifically named under my Trust Agreement shall be required to post any bond for
the faithful performance of such Trustee's responsibilities.
Section 4. Trustee Compensation
Other than when I am serving as Trustee, my Trustee shall be entitled to reasonable
compensation for services rendered. Such compensation is payable without the need of a court
order. In calculating the amount of compensation, customary charges for similar services in the
same geographic area for the same time period shall be used as guidelines. Any corporate
fiduciary shall be entitled to receive compensation for its services in accordance with its
published fee schedule in effect from time to time and any trustee who is normally compensated
on an hourly basis shall be so compensated.
My Trustee shall also be entitled to reimbursement for reasonable costs and expenses incurred
during the exercise of my Trustee's duties under my Trust Agreement.
Section 5. Change in Corporate Trustee
Any corporate successor to the trust business of any corporate trustee named under my Trust
Agreement, or acting hereunder, shall succeed to the capacity of its predecessor without re-
conveyance or transfer of trust property.
Section 6. Written Notice to Trustee
Until my Trustee receives written notice of any death or other event which triggers the right to
payments from any trust or trust shares created under my Trust Agreement, my Trustee shall
incur no liability for distributions made in good faith to persons whose interests may have been
affected by such event.
Section 7. Duty to Account
My Trustee shall render accounts, upon request, to the income beneficiaries under my Trust
Agreement at least annually, at the termination of a trust created hereunder and upon a change in
the Trustees in the manner required by law.
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Section 8. No Court Supervision
No trust or trust share created under my Trust Agreement shall require the active supervision of
any state or federal court.
13-3
Article Fourteen
Trustee Powers
Section 1. Powers
In addition to any power hereinafter specifically granted to my Trustee, it is my intention that my
Trustee have the power respecting property in my Trust Estate that ar; absolute owner of such
property would have. In accordance with such intention, any power my Trustee needs to
administer my Trust Estate, which is not hereinafter listed, shall be considered as provided for
herein. All powers shall be exercised only in a fiduciary capacity and such powers may be
exercised without the approval or supervision of any court. It is ai;>o my intension that the
Uniform Prudent Investors Act and any similar enacted statute shall not apply to govern any of
my Trustee's actions. The principles of the prudent person rule shall apply to govern the actions
of my Trustee, except that the Deceased Trustor hereby directs that its ;application be suspended
as to the Surviving Spouse acting in such a capacity.
a. Retention of Property
My Trustee shall have the power to retain any property received. into my Trust at
its inception, or later added to my Trust, without regard to v~~hether my Trust
investments are diversified, as long as my Trustee considers that retention is in the
best interests of my Trust or is in furtherance of my goals in creating my Trust.
Subject to any power of my Spouse to require underproductive .property to be
made reasonably productive, my Trustee shall have the power to invest and
reinvest in any property that may be considered by applicable; state law to be
underproductive or unproductive in nature and, specifically to be exempt from any
minimum income requirements called for under local law.
b. Additions
My Trustee shall have the power to receive additions to the asserts of the various
trusts created under my Trust Agreement from any source.
c. Business Participation
My Trustee shall have, notwithstanding any overall effect on the :fair market value
of the property held in any trust or trust share, the power to form, terminate,
continue or participate in the operation of any business enterl-rise including a
corporation, a sole proprietorship, ageneral or limited partnership (as a general or
14-1
limited partner) or a limited liability company (as a managing; or nonmanaging
member) and to effect any form of incorporation, dissolution, liquidation or
reorganization, including, but not limited to, recapitalization and reallocation of
classes of shares or other changes in the form of the business enterprise or to lend
money or make a capital contribution to any such business enterprise.
d. Make Investments
My Trustee shall have the power to invest and reinvest the assf;ts of my Trust as
my Trustee may determine to be in the best interests of my Trust without
limitation by any law applicable to investments by fiduciaries. The permitted
investments and reinvestments may include securities such. as common or
preferred stock, mortgages, notes, subordinated debentures anti warrants of any
corporation, any common trust fund administered by a corporate fiduciary, other
property, real or personal, including savings accounts and deposits, interests in
mutual or money market funds or investment trusts, annuities and insurance
whether or not such investments are unsecured or of a wasting nature. Any
corporate trustee is authorized to invest in shares of an investment management
company organized under the Investment Company Act of 1940 (commonly
known as a mutual fund) for which the corporate trustee serves as an investment
advisor, custodian, or in any other capacity, for remuneration.
e. Life Insurance
My Trustee shall have the power to obtain, by purchase or by gift or by
conversion, reissue, consolidation or by any other means, and hold as an asset of
my Trust, policies of insurance on my life or the life of any other beneficiary of
my Trust. My Trustee is authorized and empowered to exercise;, either before or
after my death, all of the rights, options, elections or privileges exercisable in
connection with such policies. These rights and options shall include, but not be
limited to, incapacity benefits, the right to borrow money with which to pay
premiums (or other charges) on any policy owned by my Trust (including any
automatic premium loan feature) or for any other trust purpose, the right to elect
among settlement options offered by the insurance company that issued such
policy, the right to convert such policy to paid-up insurancf;, extended term
insurance or to any different form of insurance, and the right to arrange for the
automatic application of dividends in reduction of premium payments (or other
charges) with regard to any policy of insurance held in my Trust Estate.
Regarding any such policies:
1. I represent that any policies of life insurance currently
transfen•ed into my Trust, or that will be transfen-ed to my
Trust hereinafter or purchased at my direction, have been
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selected (or will be selected) solely by me based on my study
and evaluation of (a) the sufficiency of the policy Ito meet the
goals of my Trust, (b) whether or not available policy
elections should be made, and (c) the current anti projected
financial strength and viability of the company issuing the
policy.
2. My Trustee has made no representations to me ~;oncerning
these policies and none of my study and evalua~:ion of the
policy or policies has been based on any representation by
my Trustee. Furthermore, my Trustee is under no obligation
to examine such policies upon receipt or to make subsequent
or periodic evaluations of same. The obligations to examine
and evaluate shall remain exclusively with me.
3. In the event that I or any beneficiary hereunder shall at any
time (1) question the sufficiency of any life insurance policy,
(2) determine that available policy elections should be made,
or {3) question the continued financial strength or viability of
the carver, it shall be their absolute obligation to inform my
Trustee of those facts in writing. My Trustee; shall be
indemnified and held harmless for any actions taken or not
taken pertaining to any such policies held by my Trust.
f. Dealing With Property
My Trustee shall have the power to acquire, grant, hold in a safe deposit box or
dispose of real or personal property of all kinds including, but not limited to, puts,
calls and options (including options on stock), for cash or on credit, including
maintaining margin accounts with brokers, at public or private sale, upon such
terms and conditions as my Trustee may deem advisable, and to ;manage, develop,
improve, exchange, partition, change the character of, or abandon property, or any
interest therein, or otherwise deal with real or personal property including, but not
limited to, the placing or releasing of liens and encumbrances on real or personal
property.
g. Environmental Compliance
Specifically, my Trustee shall have the power to use and expend my Trust income
and principal to conduct environmental assessments, audits, and site monitoring to
determine compliance with any environmental law or regulation thereunder; to
take all appropriate remedial action to contain, clean up or remove any
environmental hazard, including a spill, release, discharge or contamination,
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either on my Trustee's own accord or in response to an actual or threatened
violation of any environmental law or regulation thereunder; to institute legal
proceedings concerning environmental hazards or contest or settle any such legal
proceedings brought by any local, state or federal agencies concerned with
environmental compliance, or by a private litigant; to comply with any local, state
or federal agency order, or court order directing an assessment, abatement or
cleanup of any environmental hazards; to employ agents, consultants and legal
counsel to assist in or perform the above undertakings or actions; and, in general,
to take all appropriate actions to prevent, identify, or respond to any actual or
threatened violations of any environmental law or regulation thereunder.
No Trustee under my Trust Agreement shall be liable for any loss or depreciation
in value sustained by my Trust as a result of my Trustee retaining any property
upon which there is later discovered to be hazardous materials or substances
requiring remedial action pursuant to any federal, state or local environmental law
unless my Trustee contributed to the loss or depreciation in value through willful
default, willful misconduct, or gross negligence. Moreover, my Trustee shall not
be obligated to accept any property on behalf of my Trust withotrt my Trustee first
having the opportunity to determine, in my Trustee's discretion, that such property
is not contaminated by any hazardous or toxic materials or substances, and that
such property is not being used and has never been used for any activities directly
or indirectly involving the generation, use, treatment, storage, disposal, release, or
discharge of any hazardous or toxic materials or substances. Finally, my Trustee
shall have the power to disclaim any power that, in my Trustee;'s discretion, will
or may cause my Trustee to be considered an "owner" or "operator" of property
held in my Trust Estate under the provisions of the Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA), as amended from time to
time. This power to disclaim, as contained herein, shall apply to any such power,
whether actually set forth under my Trust Agreement, incorporated by reference
herein, or granted or implied by any statute or rule of law.
h. Borrowing Authority
My Trustee shall have the power to borrow funds from any person, including my
Trustee; to guarantee indebtedness or indemnify others in the name of my Trust
and to secure any such obligation by mortgage (including, but not limited to
reverse mortgages), pledge, security interest or other encumbrance; and to renew,
extend or modify any such obligation for a term within or extending beyond the
administration of the term of my Trust. No lender shall be bour.~d to see to, or be
liable for, the application of the proceeds of any obligation and my Trustee shall
not be personally liable for any obligation unless such Trustee .and the lender so
agree in writing.
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i. Leasing Authority
My Trustee shall have the power, with respect to real or personal properly, to
make, renew or amend for any purpose a lease, as lessor or lessee, for a term
within or beyond the term of my Trust with or without option to purchase.
j. Natural Resources
My Trustee shall have the power to enter into any arrangement or agreement,
including a lease, pooling or unitization agreement for exploration, development,
operation, conservation and removal of minerals or other natural :resources.
k. Voting Rights
iviy Trustee shaii have l'ne power to vote a secut~iy 113 person or by general or
limited proxy; to participate in or consent to any voting trusr., reorganization,
dissolution, liquidation or other action affecting any securitie~~; and to deposit
securities with, and transfer title to, a protective or other committee.
1. Title to Assets
My Trustee shall have the power to hold securities and other property whether
real or personal and whether or not in negotiable form or ir.~ the name of a
nominee (including "street name" of a broker) or by deposit to a clearing
corporation, with or without disclosure of the Trustee relationship, but my Trustee
shall be responsible for the acts of any nominee in the scope ~~f the nominee's
authorized actions with respect to such property or clearing; corporation in
connection with the property.
m. Insurance
My Trustee shall have the power to insure the assets of my Trust against any risk,
and my Trustee against liability, with respect to third persons.
n. Settlement of Disputes
My Trustee shall have the power to pay or contest any debt or claim; to
compromise, release and adjust any debt or claim; and to submit any matter to
arbitration.
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o. Payment of Expenses
My Trustee shall have the power to pay any taxes, assessments, reasonable
compensation of my Trustee and other expenses incurred in the collection,
management, care, protection and conservation of my Trust Estai:e.
p. Principal and Income
My Trustee shall have the power to allocate receipts or expe~iditures to either
income or principal and to create reserves out of income as my Trustee, in my
Trustee's discretion, deems appropriate and my Trustee's decision, made in good
faith with respect thereto, shall be binding and conclusive on all persons. This
power of allocation shall also apply to income during administr<tion of my Trust
after my death. Income during administration after my df;ath is currently
distributable.
Notwithstanding the preceding sentence, if any trust (or a share thereunder) is the
beneficiary of a Retirement Account, income earned after the parl:icipant's death in
the account shall be income of such trust or share, and if my Tru~;tee is required to
pay all of the trust income to a beneficiary, my Trustee shall collect and pay the
income of the account to the beneficiary at least quarterly. To the extent that all
of the income cannot be collected from the account, the deficielicy shall be paid
from the principal of such trust or share. Income during administration after my
death is currently distributable.
q. Distribution of Trust Property
My Trustee shall have the power to make any distribution or payment in kind or
in cash, or partly in kind and partly in cash, and to cause ,any share to be
composed of cash, property or undivided interests in property different in kind
from any other share, either pro rata or non pro rata, without regard to differences
in the tax basis of such property and without the requirement. of making any
adjustment of the shares by reason of any action taken pursuant hf;reto.
Other than as would cause a Marital or Charitable Deduction to fail or an S
election to terminate, any division, allocation, apportionment or valuation of trust
property in order to pay expenses or taxes or to distribute the assets to or among
any of the trusts, shares or beneficiaries shall be made by my 'Trustee, and the
good faith determination of my Trustee shall be binding and conclusive on all
parties. In order to maximize the benefits of my Unused Generati~~n Skipping Tax
Exemption Equivalent, my Trustee may consider the inclusion ratio of any Trust,
share or subshare when making any distribution, division, allocation or
apportionment under my Trust Agreement.
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r. Litigation
My Trustee shall have the power to prosecute or defend actions, suits, claims or
proceedings for the protection or benefit of my Trust and my Trustee in the
performance of my Trustee's duties.
s. Employment of Agents
My Trustee shall have the power to employ agents, including attorneys,
accountants, investment advisors, custodians, appraisers or others, including any
firm of which my Trustee is a member, to advise or assist my Trustee, to delegate
to them fiduciary powers and to indemnify them against liability for positions
taken in good faith and with reasonable basis.
t. Corporate Fiduciary
If any stock of a corporate trustee that is my Trustee, or of any affiliate or
successor of such Trustee, shall be included in the assets of my Trust, my Trustee
shall have full authority, in my Trustee's discretion, and notwithstanding any
regulation or rule of law to the contrary, to retain the stock and any increases
resulting from stock dividends and stock splits and from the exercise of purchase
rights and the purchase of fractional shares needed to round out fractional share
holdings that may arise concerning the stock. My Trustee shall vote such stock
either directly or by proxy. However, to the extent my Trustee; is prohibited by
law from voting such stock, my Trustee shall vote in accordance; with the written
instructions of a majority of the then living beneficiaries then entitled to current
distributions of income, or their Personal Representatives. In the event no
instruction is given, my Trustee is authorized to vote the stock in the best interests
of the beneficiaries in view of the purposes for which my Trust was created.
u. Investment Transactions
With regard to record keeping for investment transactions, my 'Trustee need not
provide copies of confirmations or similar notifications each time a trade or
investment transaction occurs, but investment transactions shall be set forth in my
Trustee's periodic accounting.
v. Repairs and Improvements
My Trustee shall have the power to make ordinary or extraorciinary repairs or
alterations in buildings or other structures, to demolish any improvements, and to
raze existing or erect new party walls or buildings or other structures.
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w. Business Personnel
My Trustee shall have the power to elect or employ directors, officers, employees,
partners or agents of any business and to compensate such persons, whether or not
any such person is a Trustee, director, officer, partner or agent cf my Trustee or a
beneficiary of my Trust.
x. Farm or Ranch Property
With respect to farm or ranch property, my Trustee shall h~~ve all necessary
powers to participate in and operate any farming (including tree farming) or ranch
operation personally or with hired labor, tenants or sharecroppers, to lease any
farm for cash or a share of crops under a lease that permits or precludes the
material participation of my Trustee to fertilize and improve the soil; to employ
conservation practices; to participate in government programs; acid to perform any
other acts deemed by my Trustee necessary or desirable to operate the property.
In making a decision whether to materially participate in farming or ranch
operations, my Trustee shall consider whether an election should be made or has
been made under Code Section 2032A to qualify for special farm-use valuation.
y. Ancillary Fiduciaries
If, for any reason, my Trustee deems it advantageous to act through an ancillary
fiduciary, my Trustee may designate an ancillary Trustee qualified to serve in the
jurisdiction where such ancillary fiduciary is to act and may delegate to such
ancillary fiduciary such of the powers granted under my Trust Agreement as my
Trustee deems advisable without being chargeable with loss, if any, arising out of
such designation or delegation. My Trustee may specify whetYier any corporate
fiduciary, or any person or persons acting in an ancillary capacit~~ hereunder, shall
serve with or without bond. Except as maybe otherwise specifically provided, no
such ancillary fiduciary need comply with the provisions of any Uniform Trustee's
Accounting Act, the Uniform Trust Act or similar acts in force iri any state where
the fiduciary maybe acting.
z. .Retention of Closely Held Interest
My Trustee shall have the power to retain any real estate interests, closely held
securities or affiliated companies or business interests, and to sell or dispose of
such interests only after careful consideration and after determi:rung that sale or
disposition is under the existing circumstances in the best interestts of my Trust or
its beneficiaries.
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aa. S Corporations
If at any time my Trust holds any stock in an S corporation, or if my Trustee
deems a Subchapter S election advisable for any corporation the stock of which is
held in my Trust, my Trustee shall take all of the necessary actions as are
necessary to continue such election in effect and, in preserving such election, may
segregate the S corporation stock, or other corporation stock for which a
Subchapter S election is to be made, from the other assets of m}~ Trust, and in my
Trustee's discretion, and otherwise consistent with the terms o:f my Trust to the
greatest extent possible, may form new trusts and may amend the terms of my
Trust Agreement as would be necessary to establish Qualified Subchapter S
Trusts to hold the said S corporation stock and assets in compliance with Code
Sections 1361(b) and 1361(d)(3) or to qualify the share of my 7Crust which holds
such shares as an Electing Small Business Trust.
bb. Exercise of Authority
Except as otherwise provided in my Trust Agreement, my Trus~:ee shall have the
power to do all acts that might legally be done by an individual in absolute
ownership and control of property.
cc. Power to Divide or Combine Trusts
My Trustee shall have the power to divide a single trust or share thereof into
separate divisions, each to be administered in accordance wii:h the terms and
conditions of the single trust, from which they were created (or iri accordance with
such terms and conditions as they may be affected by my Trustee's power to
comply with S Corporation requirements) when my Trustee, in my Trustee's
discretion, determines that division is desirable or advisable in view of tax
considerations, including considerations related to income tax, gift tax,
inheritance tax or generation skipping transfer tax or other objectives of the trusts
and their beneficiaries.
My Trustee shall not be required to make a physical segregation ~~r division of the
various trust subdivisions created under my Trust Agreement except as
segregation or division may be required by reason of the termination and
distribution of any of the trust subdivisions, but my Trustee sh;rll keep separate
accounts and records for different undivided interests.
My Trustee, in my Trustee's discretion, shall have the further power to combine
two or more trusts or trust subdivisions having substantially the same terms into a
single trust for purposes of administration when tax or other fact;ors indicate that
such combination would be desirable or advisable.
14-9
In deciding whether to combine trusts or trust subdivisions, my Trustee shall
consider the generation skipping "inclusion ratio" of the trusts or trust
subdivisions to be combined. Trusts or trust subdivisions having the same
inclusion ratios may be combined. Trusts or trust subdivision:; having different
inclusion ratios should generally not be combined unless their ir.~clusion ratios are
maintained unchanged through substantially separate and independent shares of
different beneficiaries within the meaning of Code Section 2654(b) and the
applicable regulations thereunder.
Specifically, unless there is a Personal Representative, my Trustee has the
authority to allocate any portion of my respective exemptions under Code Section
2631(a) to property as to which I am the respective transferor, including any
property transferred by myself during my lifetime as to which I did not make an
allocation prior to my death. My Trustee also has the authority to make the
special election under Code Section 2652(a)(3). If Code Section 2631(a) or
2652(a)(3) is not interpreted as to allow a Trustee to exercise such election, then a
Personal Representative shall be appointed and is authorizea~ to allocate my
respective exemptions and to exercise the said special election.
If my Trustee considers that any distribution from a trust or trust subdivision
hereunder, other than pursuant to a power to withdraw or appoint, is a taxable
distribution subject to the federal Generation Skipping Transfer Tax payable by
the distributee, my Trustee may increase the distribution by an amount that my
Trustee would estimate to be sufficient to pay that tax and arty additional tax
thereon, and shall charge the same against the trust or trust subdivision to which
the tax relates.
If my Trustee considers that any termination of an interest in m~~ Trust or a trust
subdivision hereunder is a taxable termination subject to the federal Generation
Skipping Transfer Tax, my Trustee may pay that tax from the portion of the
properly to which the tax relates without any adjustment of the relative interests of
the beneficiaries.
dd. Termination of Small Trust
If at any time after my death the costs of administration of my Trust (or any share
thereof) are of such an amount in relation to the then principal a.nd undistributed
income of my Trust (or any share thereof) that my Trustee, in my Trustee's
discretion, determines that my purposes in establishing my Trust (or any share
thereof) would no longer be served, and if my Trustee deem; it advisable to
distribute the then principal and undistributed income of my Tnist (or any share
thereof) to the then living beneficiary or beneficiaries and to thereby cause
termination of such Trust or share, my Trustee (other than any then current
14-10
beneficiary of my Trust) may do so without responsibility on the part of my
Trustee. If no such Trustee is then serving, then any Trustee may direct than an
Independent Trustee, to serve only for the purpose of determining the advisability
of termination process, be appointed pursuant to the Trustee succession provisions
of Article Three that would apply if no Trustee were then .serving; provided
however, than any Trustee who is also such a beneficiary m.ay not otherwise
participate in the appointment process.
ee. Power to Subject Trust Property to Probate
It is my intention to avoid probate through the use of my Trust. If, however, my
Trustee and Personal Representative mutually determine that it shall be in the best
interests of the beneficiaries of my Trust, and the beneficial interests of the
beneficiaries shall not thereby be altered, my Trustee may subject any asset to
probate to accomplish a result unavailable without probate. This power shall be
strictly construed and shall only be used to secure any tax or other benefit
otherwise unavailable to my Trust. Accordingly, other than a distribution that
would cause a Marital or Charitable Deduction to fail, my Trustee, in my Trustee's
discretion, may accomplish this objective by distributing sucri property to my
estate.
ff. Power to Change Sites
My Trustee shall have the power, exercisable by a written instnnnent signed and
acknowledged by my Trustee, to change the sites of any trust or trust share held
by my Trustee; and, in conjunction with any such change and without any need to
obtain the approval of any court, to elect that such trust or trust share shall be
subject to the jurisdiction of the new sites. In addition, my Trustee may move the
assets of such trust or trust share to the location of the new sittcs. The meaning
and effect of the provisions of my Trust Agreement shall be construed in
accordance with the laws of the governing state identified in Secl;ion 13 of Article
Fifteen, but each trust or trust share shall be administered in accordance with the
laws of the applicable sites. In no event, however, may this powf;r be exercised in
a manner that would cause the denial of Marital Deduction qualification for any
portion of my Trust Estate, or that would prevent a trust or trust share from
qualifying as a permitted shareholder of S corporation stock for federal income
tax purposes.
gg. Release of Trustee Powers
Each Trustee who determines it to be in the best interest of any beneficiary may,
at any time, by instrument executed with all the formalities of a deed and
delivered personally or sent by certified. mail to another then acting Trustee, if
14-11
any, or to some beneficiary of the affected Trust or Trusts, release and relinquish
or disclaim upon any terms, either in whole or in part, temporarily or
permanently, revocably or irrevocably, with or without binding successors, any
one or more of the powers, rights, authorities, and discretions conferred upon such
Trustee by any provision or provisions of my Trust Agreement or generally
pursuant to law, which release and relinquishment or disclaimer shall be binding
on all affected beneficiaries. If the release and relinquishment ~or disclaimer of a
power, right, authority, or discretion is made by less than all of the Trustees upon
whom it is conferred, such power, right, authority, or discretion. shall continue to
be exercisable in full by the Trustee or Trustees (other than any successor Trustees
on whom it is, by its terms, binding) who have not thus releaseal and relinquished
or disclaimed it.
hh. Power to Disclaim Retirement Benefits or Other Income In Respect of
Decedent ("IRD")
If I am survived by my Spouse and if my Trustee (other than my Spouse)
determines in my Trustee's discretion, that it is in the best interests of any
beneficiary of my Trust or any subdivision thereof, my Trustee may disclaim all
or any right to receive any Retirement Benefits or IlZD. I:P my Trustee so
disclaims, such disclaimed Retirement Benefits or IRD shall pass outright to my
Spouse. If my Spouse is the only Trustee at the relevant time, my Spouse may
direct that an Independent Trustee be appointed pursuant to the Trustee succession
provisions of Article Three that would apply as if I am survived by my Spouse
and no Trustee were then serving, provided, however, that my Spouse may not
otherwise participate in the appointment process.
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Article Fifteen
General Provisions
Section 1. Spendthrift Protection
Neither the principal nor the income of any trust created or contained under my Trust Agreement
shall be liable for the debts of a beneficiary nor shall the same be subject to seizure by any
creditor of any beneficiary under any lien or proceeding at law or equity. Except to the extent
otherwise expressly provided in my Trust Agreement, no beneficiary shall have the authority or
power to sell, assign, transfer, encumber or in any manner to dispose; of a beneficial interest,
whether income or principai. The iimiiations herein shaiT not restrict tiie exercise of any power
of appointment or the right to disclaim by any beneficiary.
In addition, except as to any trust or trust share intended to qualify for the Marital Deduction, or
as would cause the termination of any S corporation election, and subject to the provisions of
Section 2 of this Article, if my Trustee at a time that any distributi~~n to any beneficiary is
directed to be made under the provisions of my Trust Agreement, in such Trustee's sole
discretion, determines that reliance on government benefits, illness, substance dependency,
bankruptcy, litigation or any factor tending to diminish the ability of a beneficiary to fully benefit
from a distribution or to handle financial affairs exists, my Trustee may withhold any such
directed distribution and may extend the term of my Trust as to any portion of my Trust Estate
otherwise allotted for any so affected beneficiary. Thereafter, my 'T'rustee may continue to
distribute income or principal to such beneficiary as my Trustee may dE;termine in my Trustee's
sole discretion. If my Trustee withholds distributions to prevent a loss of, or ineligibility for,
government benefits, the Special Needs Provisions of this Article Fifteen. shall apply to such trust
property.
Section 2. The Rule Against Perpetuities
Notwithstanding any other provision of my Trust Agreement, unless sooner terminated or vested
in accordance with other provisions of my Trust Agreement, all interests not otherwise vested,
including, but not limited to, all trusts and powers of appointment created hereunder, shall
terminate: (i) one day prior to twenty-one (21) years after the death of the last survivor of the
group composed of me, my Spouse, those beneficiaries described herein and my lineal
descendants living on the date of my death or (ii) if longer, such period as may be authorized
under the laws of the state identified in the Governing State Law Section of this Article. At that
15-1
time, distribution of all principal and all accrued, accumulated and undistributed income shall be
made to the persons (or their representatives as authorized herein) then entitled to distributions of
income or principal and in the manner and proportions herein stated :irrespective of their then
attained ages.
Section 3. Incapacity and Competency
A person shall be considered incapacitated in the event such person has been determined to be so
by a court of competent jurisdiction; has been certified by two licensed physicians to be unable to
properly handle his or her own affairs by reason of physical illness or mental illness; otherwise is
unable freely to communicate for a period of 90 days; or if a trustee is prevented by state law
from exercising a power or powers granted to such trustee under this Trust Agreement. To the
extent a trustee is prevented by state law from exercising a power or powers granted to such
trustee under this Trust Agreement, the Successor Trustee shall have the power to exercise such
power or powers, provided such power is not a general power of appointment if held by a
Successor Trustee. If a Successor Trustee is prevented from exercising a power or powers
because such power or powers would constitute a general power of attorney, the trustee shall
appoint an independent trustee, as defined in Code section 672(c), to exercise such denied power
or powers. A person shall be considered to have regained capacity, as applicable, upon such a
determination by a court of competent jurisdiction, upon certification b}~ two licensed physicians
that the person is able to properly handle his or her own affairs, is able t~o freely communicate, or
if any state law proscription as to the exercise of a power or powers is removed. The term
"incapacity" is intended to be interchangeable with the terms "disability" and "incompetency".
The term "competent" in our Trust Agreement refers to a person wlio is not incapacitated.
Notwithstanding the preceding provisions of this Section, for purposes of administration under
Articles Six, Ten and Eleven of my Trust Agreement, the term "incapacitated" also refers to any
beneficiary receiving or eligible to receive government benefits.
Section 4. Income and Principal Payments
Other than as directed in the Special Needs Provisions of this Article, al.l payments of income or
principal shall be made in such of the following ways as my Trustee determines appropriate:
a. To each respective beneficiary in person upon his or her personal receipt;
b. Deposited in any bank to the credit of such beneficiary in any account carried in
his or her name or jointly with another or others;
c. To the parent or legal representative of the beneficiary;
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d. To a Custodian under a Uniform Transfers to Minors Act or Uniform Gifts to
Minors Act selected by my Trustee for such period of tame under applicable law
as my Trustee determines appropriate;
e. To some near relative, friend or institution having prirriary responsibilitty for the
care and custody of the beneficiary;
f. By my Trustee using such payment directly for the benefit of such beneficiary; or
g. To the Trustee of any revocable trust of which the beneficiary is the Trustor.
Section 5. Limit on Trustee's Discretion
ivotwithstanding any other provision in my Trust Agreement, other th,ui me and other Than my
Spouse with respect to a Survivor's Trust, no individual Trustee who is also a beneficiary
hereunder ("Trustee-beneficiary") shall have any right, power, duty or discretion concerning my
Trust Estate if such right, power, duty or discretion conferred upon such Trustee-beneficiary
under my Trust Agreement would constitute a general power of appointment under Code Section
2041 or 2514 that would cause any assets of my Trust Estate to be inchzded in the estate of such
Trustee-beneficiary. Any such right, power, duty or discretion with such effect shall be null and
void with respect to such Trustee-beneficiary. No Trustee who is under a legal obligation to any
beneficiary of my Trust Agreement or other person shall under any circumstances partake in any
decisions relating to any discretionary distributions of income or principal of my Trust Estate
that can be used to discharge any such legal obligation of such Trustee.
If however, such powers may be possessed without violating the restrictions imposed by this
Section 5 by either my Trustee jointly with an Independent Trustee, or by an Independent Trustee
alone, then my Trustee may appoint an Independent Trustee who may I~ossess those powers and
authorities without violating this Section. Such an Independent Trustee shall act jointly with my
Trustee whenever the joint possession of a power or authority would n~ct violate the restrictions
imposed by this Section. Such an Independent Trustee shall act al~cne whenever only sole
possession of a power or authority would not violate the restrictions imposed by this Section.
Section 6. No-Contest Clause
If any person or entity, other than myself, singularly or in conjunction with any other person or
entity, directly or indirectly, in any court, contests the validity of my Tnist Agreement, including
any amendments thereto, then the right of that person or entity to take any interest in my Trust
Estate or to act in any fiduciary capacity shall cease, and the demise of that person (and his or her
descendants) or entity shall be deemed to have occurred prior to mine.
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Section 7. Disclaimer by Beneficiary
Any beneficiary under my Trust Agreement shall be entitled to disclaim all or any portion of
such beneficiary's interest in my Trust.
Section 8. Captions
The captions of Articles, Sections and Paragraphs used in my 7,rust Agreement are for
convenience of reference only and shall have no significance in the construction or interpretation
of my Trust Agreement.
Section 9. Severability
Should any of the provisions of my Trust Agreement be for any reason declared invalid, such
invalidity shall not affect any of the other provisions of my Trust Agreement, and all invalid
provisions shall be wholly disregarded in interpreting my Trust Agreement.
Section 10. Statutory References
Unless the context clearly requires another construction, each statutory reference in my Trust
Agreement shall be construed to refer to the statutory section mentioned, related successor
sections, and corresponding provisions of any subsequent law, including; all amendments.
Section 11. Survivorship
a. Simultaneous Deaths
For purposes of my Trust Agreement, if my Spouse and I die under circumstances
in which the order of our deaths cannot be established, my Spouse shall be
deemed to have survived me.
If any beneficiary under my Trust Agreement, other than my Spouse, dies under
circumstances in which the order of deaths cannot be established, I shall be
deemed to have survived the beneficiary, and my Trust Agreement shall be
construed accordingly.
15-4
b. Generation Skipping Transfer Tax Matters
A person (the "Non-Skip Person") shall not be deemed to have been alive on the
date of the death of any person upon whose death a transfer is deemed to occur for
Generation Skipping Transfer Tax purposes or the date of any distribution from or
any termination of any interest in any trust or share under my Tnist Agreement for
which the date of the Non-Skip Person's death is relevant ("the 'T'ransfer Date") if:
(a) the Non-Skip Person is actually alive on the Transfer Date; (b) the Non-Skip
Person is not actually alive on the date ninety (90) days following the Transfer
Date; and (c) the existence of such a condition of survivorship causes another
person who would otherwise be assigned to a generation below that of the Non-
Skip Person to be assigned to the generation of the Non-Skip Person for
Generation Skipping Transfer Tax purposes.
Section 12. Gender and Number
In my Trust Agreement, where appropriate, except where the context; otherwise requires, the
singular includes the plural and vice versa, and words of any gender shall not be limited to that
gender.
Section 13. Governing Commonwealth Law
My Trust Agreement and the trusts created under it shall be construed, regulated and governed
by and in accordance with the laws of the Commonwealth of Pennsylvania.
Section 14. Reliance on Certificate (or Memorandum) of Trust
Any person may act in reliance upon a properly issued certificate (or memorandum) of trust
reflecting the relevant terms of my Trust Agreement without risk of incturing any liability to the
Trustor, Trustees or beneficiaries of my Trust.
Section 15. Definitions
The following terms as used in my Trust Agreement are defined as indic~~ted:
15-5
a. Beneficiary Designation
The term "Beneficiary Designation" means any document exec~zted by me which
affects the manner of payment of amounts held in a plan (af whatever type)
subject to the distribution rules of section 401(a)(9) of the Code or any
commercial annuity or any similar deferred payment arrangement.
b. Child, Children, Issue and Descendants
The terms "child" or "children" mean lawful blood descendants in the first degree
of the parent designated; and "issue" and "descendants" mean the lawful blood
descendants in any degree of the ancestor designated; provided, however, that if a
person has been adopted, that person shall be considered a child of such adopting
parent or parents, and such adopted child and his or her issue sY~all be considered
issue of the adopting parent or parents and of anyone who is by blood or adoption
an ancestor of the adopting parent or either of the adopting parents. The terms
"child," "children," "issue," "descendant" and "descendants" or those terms
preceded by the terms "living" or "then living" shall include the lawful blood
descendant in the appropriate degree of the ancestor designated even though such
descendant is born after the death of a parent. Notwithstanding the preceding
provisions of this Section 15.b, the terms of Article One exclude certain
descendants from being treated as such by restricting the availability of Trust
benefits.
c. Code
The term "Code" means the Internal Revenue Code of 1986, pis amended from
time to time. The terms "Income in Respect of a Decedent", "Gross Estate",
"Taxable Estate", "Applicable .Credit Amount", "State Death Tai: Credit", "Credit
for Prior Transfers", "Marital Deduction", "Exclusion", "Disclaimer" and any
other terms that, from the context in which they are used, refer to the Code shall
have the same meaning as such terms have for the purposes of applying the Code
to my Trust Agreement.
d. Deceased Trustor
The term "Deceased Trustor" means a Trustor who has died.
e. Death Taxes
The term "Death Taxes" means all inheritance, estate, succession and other similar
taxes that are payable by any person on account of that personi s interest in the
15-6
~ , e
estate of the decedent or by reason of the decedent's death, including penalties and
interest but excluding the following:
1. Any additional tax that may be assessed under Internal
Revenue Code Section 2032A and 2057; and
2. Any federal or state tax imposed on a Generation Skipping
Transfer, as that term is defined in the federal tax laws,
unless that Generation Skipping Transfer Tax is payable
directly out of the assets of a trust created by my Trust
Agreement.
f. Education
The term ''education'' shall be given broad interpretation arld may include but not
be limited to:
1. High School
Education at public or private elementary or high schools, including
boarding schools.
2. College
Undergraduate and graduate study in any and all fields whatsoever,
whether of a professional character in colleges or other institutions of
higher learning.
3. Specialized Training
Specialized formal or informal training in music, th.e stage, handicrafts, the
arts, or vocational or trade schools, whether by private instruction or
otherwise.
4. Other Educational Activities
Any other activity including foreign or domestic travel that shall tend to
develop fully the talents and potentialities of each beneficiary regardless of
age.
g. Heirs at Law
References to someone's "heirs at law" mean individuals who are living at the
event when property is directed to be distributed to them. Those individuals'
15-7
identities and the shares of the distributable property that: they each receive shall
be determined under the intestacy laws of the Commonwealth of Pennsylvania
which then govern the distribution of the personal property of a resident dying
then, without creditors, owning only the distributable assets.
h. Independent Trustee
The term "Independent Trustee" means a Trustee who is an independent person
who, within the meaning of Code section 672(c), is not related or subordinate to
any beneficiary of my Trust.
i. Personal Representative
The term "Personal Representative" means trustee, executor, executrix,
administrator, administratrix, conservator, guardian, custodian or any other "type
of personal representation.
j. Per Stirpes
In every case in which a disposition of an interest is to be made to the issue of a
person "per stirpes," it is intended that such disposition shall be made in
accordance with the principle of representation. This principle in relation to my
Trust Agreement means that whenever property is to be distributed to the issue of
a person, such property shall be divided into as many shares as there are, at the
time of disposition, living issue in the nearest degree of kinship to such person
and then deceased issue in the same degree who left issue who are then living;
each then living issue in the nearest degree receiving one share, and the share of
each then deceased issue in the same degree being divided among his or her issue
in the same manner.
k. Retirement Account/Retirement Benefits
The terms "Retirement Account" or "Retirement Benefits" mean any deferred
payment account, whether or not considered a qualified plan under sections 401,
403, 408 or any other section of the Code, under which by reason of fiduciary
accounting principles income is considered earned but not immediately payable.
1. Retirement Account Trustee
1. For purposes of receiving any Retirement Benefits, the
Trustees of the Family Trust and Survivor's Trust may be
referred to by the term "Retirement Account Trustee". If
there is more than one Trustee serving as Trustee of either or
15-8
•
both the Family Trust and the Survivor's Trust, then for
purposes of my Trust Agreement, all such Trustees shall be
included in the term "Retirement Account Trustee". This
definition of Retirement Account Trustee is intended to
provide an efficient means to utilize a Beneficiary
Designation to indicate the beneficiary of any Retirement
Account benefits.
2. The Trustees of the Family Trust and the Survivor's Trust
(collectively known, and previously referred to, as the
"Retirement Account Trustee") shall divide all Retirement
Account balances (the "Balance"), or rights thereto, between
the Family Trust and the Survivor's Trust in accordance with
the fractional formula division of income in respect of a
decedent set out in Article Six; however, relative to such
formula: (i) only property affected by a Beneficiary
Designation shall comprise the denominator of the fraction;
and, (ii) any such division of the Balance shall be determined
only after taking into account the other fractional formula
allocations directed under Article Six. Notwithstanding the
preceding, any part of any balance allocable hereunder to a
Survivor's Trust as to which my Spouse has anon-lapsing
general power of appointment over all principal shall be
distributed to my Spouse, free of trust, instead of to such
Survivor's Trust. If my Spouse disclaims this outright
distribution, it shall pass to such Survivor's Trust.
3. This Retirement Account Trustee arrangement is intended,
and shall be interpreted for all purposes, to comply with the
applicable requirements of the Code and Treasury
Regulations, to obtain treatment of trusts and trust
beneficiaries as Designated Beneficiaries under Code section
401 (a)(9), as amended. Pursuant to such intent, other than
as the provisions of Article Twelve may apply, no part of any
balance shall be allocated, in trust or otherwise, for the
benefit of any beneficiary who is not an individual.
m. Trust Estate
The term "Trust Estate" means all of the property, real and personal, intangible
and tangible, that has been transferred to my Trustee, whether or not listed on any
Schedules.
15-9
~ ,~ •
n. Trustee's Discretion
The term "discretion" with regard to a Trustee means such Trustee's sole but
reasonable judgment. In exercising any discretionary power with respect to my
Trust, my Trustee shall at all times act in accordance with fiduciary principles and
shall act reasonably under the circumstances and not in bad faith or in disregard of
the purposes of my Trust.
o. Trustor
The term "Trustor" shall be interchangeable with the terms "settlor", "grantor",
"donor" or other similar terms.
p. Unused Generation Skipping Tax Exemption Equivalent
The term "Unused Generation Skipping Tax Exemption Equivalent" means the
Generation Skipping Transfer Tax exemption provided in section 2631 of the
Code in effect at the time of death of a Trustor, reduced by the aggregate of (1)
the amount, if any, of such exemption allocated by such Trustor or by operation of
law to such Trustor's lifetime transfers and (2) the amount, if any, such Trustor or
such Trustor's Personal Representative or Trustee has specifically allocated to
property other than property to which such exemption is directed to be allocated
by any applicable provision of my Trust Agreement.
For purposes of my Trust Agreement, if at the time of death of a Trustor such
Trustor has made lifetime transfers of property to which an inclusion ratio of
greater than zero would be applicable and for which the gift tax return due date
has not expired (including extensions) and a return has not yet been filed, it shall
be deemed that the generation skipping transfer exemption has been allocated to
such transfers to the extent necessary and possible to exempt such transfers from
Generation Skipping Transfer Tax.
q. Unused Applicable Credit Equivalent
The term "Unused Applicable Credit Equivalent" means that value of a Deceased
Trustor°s taxable estate determined without regard to the Marital Deduction that
can be transferred at death without causing any federal estate tax liability because
o£
1. Any available Applicable Credit Amount (Unified
Credit),
15-10
~ .~ w
2. The Credit for State Death Tax to the extent it does
not increase the amount of death taxes payable to any
state,
3. The Credit for Prior Transfers,
4. Allowable Exclusions from the Gross Estate,
and that is in excess of the net value of all property includable in the taxable estate
of a Deceased Trustor that does not qualify for the Marital Deduction or any other
deduction; whether that value passes outside of my Trust (by way of joint
tenancy, life insurance contract, Beneficiary Designation, will, or otherwise) or
under other provisions of my Trust.
Section 16. Special Needs Provisions
a. Overall Limitation on Distribution
It is my intention that the assets of my Trust Estate supplement but not supplant,
impair or diminish any then existing forms of support or benefit which the
beneficiary is receiving or becomes eligible to receive. For purposes of this
Section, the term "support" means food, clothing or shelter. The terms of my
Trust Agreement shall be read and interpreted to prevent any action by my
Trustee which would supplant, impair, diminish or otherwise interfere with, limit
or reduce the beneficiary's receipt of, or eligibility for any form of government or
private benefits. Any power of distribution (whether or not exercised), granted
my Trustee pursuant to the terms of my Trust Agreement, that would result in the
loss, diminishment or ineligibility for government or private benefits, is hereby
revoked; and, only such powers as will not result in ineligibility for such benefits,
or loss, diminishment or impairment, thereof, shall remain exercisable by my
Trustee.
b. Special Needs
For purposes of my Trust Agreement, the term "Special Needs' refers to
supplemental, non-support expenditures from my Trust's assets that, pursuant to
the other provisions of this Section, my Trustee is authorized to disburse, in my
Trustee's sole and absolute discretion. Special Needs, subject to the general
supplemental, non-support limitation, include, but are not limited to, medical,
dental, diagnostic or therapeutic treatment, or nursing or home care services for
which the beneficiary is not receiving, and is not eligible to receive government or
private benefits. Special Needs also includes the differential between any
15-11
~ ~~ ~
treatment, service or care that the beneficiary is receiving from any government or
private source and the level of treatment, service or care my Trustee deems
appropriate for the beneficiary. Disbursements for education, travel (including
travel by those my Trustee believes the companionship of which will benefit the
beneficiary), entertainment devices or events and electronic devices are also to be
considered Special Needs.
c. Distribution of Income or Principal
1. Distributions for Special Needs
Subject to the preceding provisions of this Section, that prohibit my
Trustee from making any distribution which would supplant, impair
or diminish goverrunent or private benefits, or cause the beneficiary
to be ineligible for such benefits, as determined in my Trustee`s sole
and absolute discretion, my Trustee may distribute such amounts of
income or principal for the Special Needs of the beneficiary. My
Trustee may act arbitrarily and without regard to any statutes or
other rules of law in refusing to disburse tn~st assets. No
distributions may be made to the beneficiary. Any distributions
made shall be made to the goods or services provider.
2. Accumulated Income
Any income not distributed shall be accumulated and added to
principal.
3. Resources of the Beneficiary
My Trustee, in exercising discretion under this Section, shall
consider all income or resources available to the beneficiary. The
beneficiary has no rights to any distributions under my Trust.
4. Treatment of Any Residence Held by My Trust
My Trustee may charge the beneficiary rental on any residence
owned by my Trust. My Trustee must charge rent if the failure to do
so would impair, diminish, or cause ineligibility for, any government
or private benefits.
15-12
~ ~~
5. Rights of Creditors and Others
My Trust assets are not intended to be used for the support of the
beneficiary, but are only intended to supplement, in my Trustee's
sole and absolute discretion, resources, income or government or
private assistance available to the beneficiary. No part of my Trust
Estate, neither principal nor income, shall be subject to anticipation
or assignment by the beneficiary, nor be subject to attachment by
any creditor of the beneficiary, governmental agencies or any other
individual or entity; including any who may have provided goods or
services to the beneficiary.
6. Power to Terminate the Beneficiary's Share of My Trust
If my Trustee deems it necessary to terminate the beneficiary's share
of my Trust to avoid impairing or diminishing the beneficiary's
receipt of government or private benefits, or becoming ineligible for
such benefits, my Trustee, in my Trustee's sole and absolute
discretion, shall terminate the beneficiary's share of my Trust. If my
Trustee terminates the beneficiary's share of my Trust, the assets of
the beneficiary's share of my Trust shall be held, administered and
distributed pursuant to the following provisions of this Section as
though the beneficiary had died. I request, but do not require, that
the remainder beneficiaries consider the purposes of the beneficiary's
share of my Trust in expending the property they receive.
7. Distributions on Death of Beneficiary
Unless provided otherwise under the provisions of preceding
Articles, if such beneficiary should die while my Trustee still holds
trust assets for such beneficiary's benefit, such beneficiary's share of
my Trust shall lapse and my Trustee shall distribute the balance of
the trust share to such beneficiary's then living descendants, per
stirpes.
If such beneficiary has no then living descendants, my Trustee shall
distribute such beneficiary's trust share to such beneficiary's siblings,
per stirpes. If such beneficiary has no then living siblings, my
Trustee shall distribute such beneficiary's trust share to my then
living descendants, per stirpes.
15-13
s M
If I have no then living descendants, my Trustee shall distribute the
balance of the beneficiary's share of my Trust as provided in Article
Twelve of my Trust Agreement.
Subject to the other provisions of this Section, my 'Trustee may pay
for the expenses of the beneficiary's last illness and funeral.
I have executed my Trust Agreement on the date set forth on the first page of my Trust
Agreement.
I certify that I understand my Trust Agreement and that it correctly states the terms and
conditions under which my Trust Estate is to be held, managed and disposed of by my Trustee. I
approve this revocable living trust in all particulars and request my Trustee to execute it.
Trustor:
W. WADDINGTON
Trustees:
W. WAD INGTON HAROLD T. WADDINGTON
15-14
r ~•. r
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
SS
On this %:: i ~ ~~ ~~ ,before me, a notary public, the undersigned officer, personally
appeared ANNE W. WADDINGTON, Trustor and Trustee, known to me (or satisfactorily proven) to
be the person whose name is subscribed to the within instrument and acknowledged that she
executed the same for the purposes therein contained.
In witness whereof I hereunto set my hand and official seal.
Notary Public
! ~ ''t,Si
E ~~' ~ r ~~;~~ (` Potary Publia
~;!~c;y , ar!~ . ,, u~,;;:~ County
!v4y ~.~cytri;`r~;ssu~rx C::xp;ras Nov. 8, 2003
(SEAL)
COMMONtiVEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
SS
On this ~~ `~ ~' ,before me, a notary public, the undersigned officer, personally
appeared HAROLD T. WADDINGTON, Trustee, known to me (or satisfactorily proven) to be the
person whose name is subscribed to the within instrument and acknowledged that he executed
the same for the purposes therein contained.
In witness whereof I hereunto set my hand and official seal.
Notary Public
(SEAL)
Prepared by:
James, Smith, Durkin & Connelly LLP
134 Sipe Avenue, Hununelstown, PA 17036
Phone: (717) 533-3280 Fax: (717) 533-2795
jsdinfo@j sdlegal.com
Mailing Address:
P.O. Box 650, Hershey, PA 17033
Not~irir.~f SFaI
Linda L Fetter!~off, !~!otary I~ub!ic
Derry Twp., Dauphin County
My Comrnission L=xpiras I'drr,. 8, 2003
15-15
REGISTER OF WILLS OF
INVENTORY
CUMBERLAND
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF Cumberland } SS File Number
Thomas V. Waddington, John F. Waddington and Ruth A. Patrick
Personal Representative(s) of the Estate of Anne W. Waddington `~= ~'~ ==a
--- - - - - - f.r, --~ -=,-
deceased, depose(s) and say(s) that the items appearing in the following inventory include all of the personal'~ss"~ ~ wher~er +
situate and all of the real estate in the Commonwealth of Pennsylvania of said Decedent, that the valuation p1a_~Rppositg eack~ _
item of said inventory represents its fair value as of the date of the decedent's death, and that Decedent own~'no real mate -
outside of the Commonwealth of Pennsylvania except that which appears in a memorandum at the end of this~{tventory„-.
I verify that the statements made in this Inven-
tory are true and correct. I understand that false state-
ments herein are made subject to the penalties of
18 Pa.C.S. § 4904 relating to unsworn falsification to
authorities.
Attorney -- (Name)
(Firm)
(Address)
(Telephone)
Gary L. James Esq.
(3upreme Court I.D. No.) 27752
.lamPC_ Smith_ Dietterick 8 Connelly- LLP
134 Sipe Avenue, Hummelstown, PA 17036
717/533-3280
DATE OF DEATH tAST RESIDENCE 723 Oak Oval DECEDENTS SOC. SEC. NO.
08/28/2007 Mechanicsburg, PA 17055 238-46-3672
FIGURES MUST BE TOTALED
Personal Propert
Cash ...............................................................................................
Personal Property .........................................................................
Stocks/Listed .................................................................................
Stocks/Closely Held ......................................................................
Bonds .............................................................................................
Partnerships and Sole Proprietorships .....................................
Mortgages and Notes Receivable ...............................................
All Other Property .........................................................................
Total Personal Property .........................................
Total Real Property ...........................................
Total Personal and Real Property .........................
COUNTY, PENNSYLVANIA
21-07-0869
170,544.30
N
170,544.30
170,544.30
NOTE: The Memorandum of real estate outside the Commonwealth of Pennsylvania may, at the election of the personal re{xesentative include the value of each
item, but such figures should not be extended into the total of the Inventory. (See 20 Pa. C.S. § 3301(b))
Fam RW-09 Rev. io-t~-zoos
i INVENTORY
REGISTER OF WILLS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH OF PENNSYLVANIA } SS
COUNTY OF Cumberland } File Number 21-07-0869
DATE OF DEATH LAST RESIDENCE 723 Oak Oval DECEDENTS SOC. SEC. NO.
08/28/2007 Mechanicsburg, PA 17055 238-46-3672
Cash
M 8~ T Bank Certificate of Deposit # 31003913916664 -valued per letter dated
October 10, 2007
Accrued interest on above item through date of death
M 8 T Bank Checking Account # 88035840 -valued per letter darted October 10,
2007
Accrued interest on above item through date of death
M 8: T Individual Retirement Account # 35004110100902 -valued) per letter
dated October 10, 2007 -Beneficiary is Estate
Messiah Village -entrance fee refund
ML Bank Deposit Program -held in the Merrill Lynch Brokerage Account #
872-54219 -valued per statement
U.S. Treasury - 2007 refund
Total Cash
17,910.60
127.96
50,316.00
1.16
19,707.80
77,050.78
3,497.00
1,933.00
170,544.30
(Attach additional sheets if necessary) Total Personal Property and Real Estatte 170,544.30
May 21, 2008
,„ . i
Glenda Farner Strausbaugh EJ 1L-11
Register of Wills & S~C V itLT l
Clerk of Orphans' Court ~
~ ~
''
~ `
1 Courthouse Square -
-
Carlisle, PA 17013
ItE: ESTATE OF ANNE W. WADDINGTON, DECEASED
FILE N0.21-07-0869
Denise M. Long
dml@jsdc.com
Dear Ms. Strausbaugh:
Enclosed are the following documents to be filed in the above-referenced Estate:
1. An original and two (2) copies of the Pennsylvania Inheritance Tax
Return.
2. An original and one (1) copy of the Inventory.
3. A check made payable to the "Register of Wills, Agent" in the amount of
Five Thousand Six Hundred Twenty Five Dollars and Sixty Two Cents
($5,625.62) representing the balance of Pennsylvania Inheritance Tax due.
4. A check made payable to the "Register of Wills, Cumberland County" in
the amount of Thirty Dollars ($30.00) representing the filing fee.
5. A copy of the Trust Document.
6. A copy of the Will.
Please time-stamp the additional copies of the Return and Inventory and return them to
me in the enclosed self-addressed, stamped envelope.
If you have any questions, please feel free to give me a call.
Sincerely,
.TAMES, SMITH, DIETTERICK & ONNELLY, LLP
c
r
Denise M. Long
Cc: Thomas V. Waddington
134 SIPE AVENUE
HUMMELSTOWN, PA 17036
MAILING ADDRESS
PO BOX 650
HERSHEY, PA 17033
TOLL FREE 1.800.942.3660
TEL. 717.533.3280
FAX 717.533.7771
www.jsdo.com
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