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HomeMy WebLinkAbout07-09-0815056041147 REV-1500 EX (06-05) OFFICIAL USE ONLY PA Department of Revenue County Code Year File Number Bureau of Individual Taxes INHERITANCE TAX RETURN 2 1 0 7 1 0 9 3 PO BOX.280601 Harrisburg, PA 17128-0601 RESIDENT DECEDENT ENTER DECEDENT INFORMATION BELOW Social Security Number Date of Death Date of Birth 222440145 10092007 02141907 Decedent's Last Name Suffix Decedent's First Name MI BELLANCA MARY G (If Applicable) Enter Surviving Spouse's Information Below Spouse's Last Name Suffix Spouse's First Name MI BELLANCA LEONARD Spouse's Social Security Number 2 2 2 2 4 9 9 7 7 THIS RETURN MUST BE FILED IN DUPLICATE WITH THE REGISTER OF WILLS FILL IN APPROPRIATE OVALS BELOW ® 1. Original Return ^ 2. Supplemental Return ^ 3. Remainder Return (date of death prior to 12-13-82) 4. Limited Estate 4a. Future Interest Compromise ^ (date of death after 12-12-82) ^ 5. Federal Estate Tax Return Required ^ g Decedent Died Testate ® ~ Decedent Maintained a Living Trust 0 8. Total Number of Safe De o (Attach Copy of Will) (Attach Copy of Trust) p Slt Boxes ^ 9. Litigation Proceeds Received ^ 1 p. Spousal Poverty Credit (date of death between 12-31-91 and 1-1-95) ^ 11. Election to tax under Sec. 9113 A ( ) (Attach Sch. O) ,C,ORRESPONDENT -THIS SECTION MUST BE COMPLETED. ALL CORRESPONDENCE AND CONFIDENTIAL TAX INFORMATION SHOULD BE DIRECTED TO: name Daytime Telephone Number RICHARD E. CONNELL 717232731 ~ Firm Name (If Applicable) ~ ~ BALL , M U R R E N & C O N N E L L ~ REGISTER O[~.yID It LS US~@NLY -- -; ~ ~ First line of address ~~ c~> ~j f `--~ ; j ~ 23 03 MARKET STREET `` 'c~,~ ~ ~_? C.-'' C. ~ t ~ ._~ ,~ -n Second line of address ~ ~` ? --r N = - T ,e- :. City or Post Office State ZIP Code DATE FILED ~ CAMP HILL PA 17011 Correspondent's a-mail address: C O ri n e l l C~ b m C - l a w .Tie t Under penalties of perjury, I declare that 1 have examined this return, including accompanying schedules and statements, and to the best of my knowledge and belief, it is true correct and complete. Declaration of preparer other than the personal representative is based on all information of which preparer has any knowledge. SIGNA RE OF PERSON RESPONSIBLE FO I).ING R TURN ~ QTF~ G Leonard C. Bellanca/'%- D~ 112 Leyton Way, Mech~s~rg, PA 17055 SIGNAT OF PREPA OTHE N RE ESEI,ITAT DAT Richard E. Connell, Esquire ADDRESS 2303 Market Street, Camp Hill, PA 17011 Side 1 15056041147 15056041147 J REV-1500 EX 15056042148 oe~ede~rs Name: B E L LA N C A, MARY G. RECAPITULATION 1. Real Estate (Schedule A) .......................................................................................... 1. 2. Stocks and Bonds (Schedule B) ............................................................................... 2. 3. Closely Held Corporation, Partnership or Sole-Proprietorship (Schedule C).......... 3. 4. Mortgages & Notes Receivable (Schedule D) .......................................................... 4. 5• Cash, Bank Deposits & Miscellaneous Personal Property (Schedule E) ................ 5. 6. Jointly Owned Property (Schedule F) ^ Separate Billing Requested ............. 6. 7. Inter-Vivos Transfers & Miscellaneous Non-Probate Property (Schedule G) ^ Separate Billing Requested ............. 7, 8. Total Gross Assets (total Lines 1-7) ....................................................................... 8. 9. Funeral Expenses & Administrative Costs (Schedule H) ......................................... 9. 10. Debts of Decedent, Mortgage Liabilities, & Liens (Schedule I) ................................ 10. 11. Total Deductions (total Lines 9 & 10) ...................................................................... 11. 12. Net Value of Estate (Line 8 minus Line 11) ............................................................. 12. 13. Charitable and Governmental Bequests/Sec 9113 Trusts for which an election to tax has not been made (Schedule J) ................................................. 13. 14. Net Value Subject to Tax (Line 12 minus Line 13) .......................................... ....... 14. TAX COMPUTATION -SEE INSTRUCTIONS FOR APPLICABLE RATES 15. Amount of Line 14 taxable at the spousal tax rate, of transfers under Sec. 9116 (a)(1.2) X .00 15. 16. Amount of Line 14 taxable at lineal rate X .045 16. 17. Amount of Line 14 taxable at sibling rate X .12 17. 18. Amount of Line 14 taxable at collateral rate X .15 18. 19. Tax Due ....................................................................................:................................ 19. 20. FILL IN THE OVAL IF YOU ARE REQUESTING A REFUND OF AN OVERPAYMENT. Decedent's Social Security Number 222440145 156,926.90 564,095.39 0.00 721,022.29 8,247.14 33,460.76 41,707.90 679,314.39 679,314.39 0.00 0.00 ~~~~~ Side 2 15056042148 15056042148 J REV-1500 EX Page 3 Decedent's Complete Address: File Number 21 - 07 - 1093 Bellanca, Mary G. _ STREET ADDRESS 4905 East Trindle Road CITY STATE ZIP Mechanicsburg PA 17055 Tax Payments and Credits: 1. Tax Due (Page 1 Line 19) 2. CreditslPayments A. Spousal Poverty Credit B. Prior Payments C. Discount (1) 0.00 3. Interest/Penalty if applicable Total Credits (A + B + C) (2) 0.00 p, Interest E. Penalty Total InteresUPenalty (D + E) (3) 0.0 0 4, If Line 2 is greater than Line 1 + Line 3, enter the difference. This is the OVERPAYMENT. (4) Check box on Page 2 Line 20 to request a refund 5, If Line 1 + Line 3 is greater than Line 2, enter the difference. This is the TAX DUE. (5) 0.00 A, Enter the interest on the tax due. (5A) g. Enter the total of Line 5 + 5A. This is the BALANCE DUE. {5B) Q , Q Q Make Check Payable to: REGISTER OF W/LLS, AGENT PLEASE ANSWER THE FOLLOWING QUESTIONS BY PLACING AN "X" IN THE APPROPRIATE BLOCKS 1. Did decedent make a transfer and: Yes No a. retain the use or income of the property transferred :.................................................................................. (^ ~x~ b. retain the right to designate who shall use the property transferred or its income :.................................... ^ ~x c. retain a reversionary interest; or .................................................................................................................. [~ ~~ d. receive the promise for life of either payments, benefits or care? .............................................................. ~ [~ 2. If death occurred after December 12, 1982, did decedent transfer property within one year of death without receiving adequate consideration? ....................................................................................................................... ^ 3. Did decedent own an "in trust for" or payable upon death bank account or security at his or her death?......... ^ 4. Did decedent own an Individual Retirement Account, annuity, or other non-probate property which contains a beneficiary designation? ...................................................................................................................... ^ ~~ IF THE ANSWER TO ANY OF THE ABOVE 4UESTIONS IS YES, YOU MUST COMPLETE SCHEDULE G AND FILE IT AS PART OF THE RETURN. For dates of death on or after July 1, 1994 and before January 1, 1995, the tax rate imposed on the net value of transfers to or for the use of the surviving spouse is three (3) percent [72 P.S. §9116 (a) (1.1) (i)). For dates of death on or after January 1, 1995, the tax rate imposed on the net value of transfers to or for the use of the surviving spouse is zero (0) percent [72 P.S. §9116 (a) (1.1) (ii)J. The statute does not exempt a transfer to a surviving spouse from tax, and the statutory requirements for disclosure of assets and filing a tax return are still applicable even if the surviving spouse is the only beneficiary. For dates of death on or after July 1, 2000: The tax rate imposed on the net value of transfers from a deceased child twenty-one years of age or younger at death to or for the use of a natural parent, an adoptive parent, or a stepparent of the child is zero (0) percent [72 P.S. §9116 (a) (1.2)]. The tax rate imposed on the net value of transfers to or for the use of the decedent's lineal beneficiaries is four and one-half (4.5) percent, except as noted in 72 P.S. §9116 1,2) [72 P.S. §9116 (a) (1)]. The tax rate imposed on the net value of transfers to or for the use of the decedent's siblings is twelve (12) percent [72 P.S. §9116 (a) (1.3)]. A sibling is defined under Section 9102, as an individual who has at least one parent in common with the decedent, whether by blood or adoption. COMMONWEALTH OF PENNSYLVANIA INHERITANCE TAX RETURN RESIDENT DECEDENT SCHEDULE B STOCKS & BONDS ESTATE OF Bellanca, Mary G. FILE NUMBER 21 - 07 - 1093 All property jointly-owned with right of survivorship must be disclosed on Schedule F. ITEM DESCRIPTION NUMBER 1 rVanguard a. Energy Fund Investor (367.062 shares) Unit Value - $82.23 each 2 3 4 Vanguard b. PRIMECAP Core Fund (3430.291 shares) Unit Value - $14.42 each Vanguard c. Windsor II Fund Investor (860.270 shares) Unit Value - $38.40 each Vanguard d. Selected Value Fund (2033.552 shares) Unit Value - $22.34 each 5 Lucent - 390 shares i Unit Value $4.653 each UNIT VALUE ~ VALUE AT DATE OF DEATH 30,183.51 46,464.80 33,034.37 45,429.55 1,814.67 TOTAL (Also enter on line 2, Recapitulation) j 156,926.90 SCHEDULE E CASH, BANK DEPOSfTS, & MISC. COMMONWEALTH OF PENNSYLVANIA PERSONAL PROPERTY INHERITANCE TAX RETURN RESIDENT DECEDENT FILE NUMBER ESTATE OF Bellanca, Matt' G. 21 - 07 - 1093 Include the proceeds of litigation and the date the proceeds were received by the estate. All property jointly-owned with the right of survivorship must be disclosed on schedule F. ITEM VALUE AT DATE OF NUMBER DESCRIPTION DEATH 1 Vanguard 564,095.39 Prime Money Market Fund TOTAL (Also enter on Line 5, Recapitulation) ~ 564,095.39 SCHEDULE F COMMONWEALTH OF PENNSYLVANIA JOINTLY-OWNED PROPERTY INHERITANCE TAX RETURN RESIDENT DECEDENT ESTATE OF Bellanca, Mary G. FILE NUMBER 21 - 07 - 1093 If an asset was made joint within one year of the decedent's date of death, it must be reported on schedule G. A SURVIVING JOINT TENANT(S) NAME Leonard Bellanca ADDRESS 4905 East Trindle Road Mechanicsburg, PA 17055 JOINTLY OWNED PROPERTY: ITEM LETTER DATE C~FfSCRlPT.10~ C~F PRO~ERTY Include name o Inanclal Ins I u Ion an bank account number % OF DATE OF DEATH DATE OF DEATH NUMBER FOR JOINT MADE or similar identifying number. Attach deed forjointly-held real DECD'S VALUE OF VALUE OF ASSET INTEREST DECEDENT'S INTEREST TENANT JOINT estate. _ 1 A 03/10/2005 Wachovia Sank N.A. 26,835.31 0% 0.00 RELATIONSHIP TO DECEDENT Husband TOTAL (Also enter on line 6, Recapitulation) ~ 0.00 SCHEDI~.E H FUNF~tAL EXPENSES & COMMONWEALTH OF PENNSYLVANIA INHERITANCE TAX RETURN ~~ ~~ RESIDENT DECEDENT ESTATE OF Bellanca, Mary G. FILE NUMBER 21 - 07 - 1093 Debts of decedent must be reported on Schedule I. ITEM i NUMBER ~ FUNERAL EXPENSES: DESCRIPTION AMOUNT A. 1 i Malpezzi Funeral Home B. 1 2 3 a. 5. 6. 7. 1 ADMINISTRATIVE COSTS: Personal Representative's Commissions Social Security Number(s) / EIN Number of Personal Representative(s): Street Address City State Zip Year(s) Commission paid Attorney's Fees Ball, Murren & Connell Family Exemption: (If decedent's address is not the same as claimant's, attach explanation) Claimant Street Address City State Zip Relationship of Claimant to Decedent Probate Fees Register of Wills -Cumberland County Accountant's Fees Tax Return Preparer's Fees Other Administrative Costs TOTAL (Also enter on line 9, Recapitulation) 7,026.56 610.58 610.00 8,247.14 SCHEDULEI ~ DEBTS OF DECEDENT, MORTGAGE COMMONWEALTH OF PENNSYLVANIA LIABILITIES & LIENS INHERITANCE TAX RETURN ~ RESIDENT DECEDENT FILE NUMBER i ESTATE OF Bellanca, Mary G. 21 - 07 - 1093 Include unreimbursed medical expenses. ITEM ~ DESCRIPTION NUMBER AMOUNT 1 Internal Revenue Service 32,664.00 (2007 personal income tax paid after date of death) 2 Pennsylvania Department of Revenue 784.00 (2007 personal income tax paid after date of death} 3 Burick/Azizkhan, M.D. 12.76 TOTAL (Also enter on Line 10, Recapitulation) ~ 33,460.76 REV-1513 EX+ (9-00) COMMONWEALTH OF PENNSYLVANIA INHERITANCE TAX RETURN RESIDENT DECEDENT ESTATE OF Bellanca, Mary G. SCHEDULE) BENEFICIARIES FILE NUMBER NUMBER ~ NAME AND ADDRESS OF PERSON(S) RECEIVING PROPERTY I. TAXABLE DISTRIBUTIONS [include outright spousal distributions, and transfers under Sec. 9116 (a) (1.2)] 1i 2 3 4 5 ~ 21 - 07 - 1093 RELATIONSHIP TO SHARE OF ESTATE AMOUNT OF ESTATE DECEDENT (Words) ($$$) Do Not List Trustee(s) i Enter dollar amounts for distributions shown above on lines 15 through 18, as appropriate, on Rev 1500 cover sheet II. NON-TAXABLE DISTRIBUTIONS: A. SPOUSAL DISTRIBUTIONS UNDER SECTION 9113 FOR WHICH AN ELECTION TO TAX IS NOT BEING MADE 1 i Transfer to Spousal Trust under Trust (attached) f 679,314.39 B. CHARITABLE AND GOVERNMENTAL DISTRIBUTIONS TOTAL OF PART II -ENTER TOTAL NON-TAXABLE DISTRIBUTIONS ON LINE 13 OF REV-1500 COVER SHEET 679,314.39 STATE OF SOUTH CAROLINA } REVOCABLE TRUST AGREEMENT COUNTY OF BEAUFORT ) THIS TRUST AGREEMENT, made and entered into April 15, 1997, by and between MARY G. BELLANCA (hereafter referred to as the "Grantor"), and MARY G. BELLANCA and LEONARD BELLANCA (hereafter referred to as the "Initial Co- Trusfees"), sets forth the terms and trusts upon which property received by the Trust for the purpose of this Agreement is to be held. NAME OF TRUST This Trust shall hereafter be referred to as the "Mary G. Bellanca Revocable Trust dated April 15, 1997_" WITNESSETH: THE GRANTOR HEREBY DECLARES that the Grantor is married to LEONARD BELLANCA, who is hereafter referred to as the "Grantor's spouse." THE GRANTOR HEREBY DECLARES that LEONARD C. BELLANCA, of Mechanicsburg, Pennsylvania, JAMES A. BELLANCA, of Winnetka, Illinois, JOSEPH J. BELLANCA, of Malvern, Pennsylvania, PAUL M. BELLANCA, of Honolulu, Hawaii, and MARY ANN SLATTERY, of Midliothian, Virginia, are children of the Grantor and, together with any children hereafter adopted by the Grantor, are hereafter referred to as the "'Grantor's children." Any person not included in the definition of "Grantor's children" in the preceding sentence has been intentionally omitted and neither such person, nor any issue thereof, shall be entitled to share in any bequest or privilege granted to any or all of the Grantor's children, or their issue, pursuant to the terms of this Agreement. All funds and other properties hereafter delivered, transferred, conveyed or bequeathed to this Trust, or to any person or entity as the Trustee hereof, at any time or from time to time, by the Grantor or by any other person or entity (hereafter referred to, in total, as the "Trust Estate"}, are to be held by the Trustee, IN TRUST, and are to be invested, reinvested, administered and distributed upon the terms and conditions set forth below: ARTICLE I A. The Grantor, while serving as Initial Trustee or Co-Trustee, may manage, invest, and distribute income and principal however the Grantor so desires. Whenever any other person or entity is serving as Trustee, the Trustee shall be obligated to distribute all net income to the Grantor in convenient insta{Iments not less frequently than quarter-annually. Unless the Grantor has been determined to be incompetent pursuant to the provisions of ARTICLE XVIII hereafter, and so remains, the Trustee shall also be obligated to distribute to the Grantor such principal of the Trust Estate as the Grantor requests in writing from time to time; provided, however, such request(s) may not be made by any representative, agent, conservator, or attorney-in fact of the Grantor. B. Notwithstanding the foregoing, whenever the Trustee determines, in the Trustee's sole judgment, that because of any physical or mental illness or disability the Grantor is not fully capable of managing financial matters, the Trustee may apply income for the benefit of the Grantor, distributing only the balance to the Grantor. In addition, the Trustee steal{ then also apply such sums from the principal of the Trust Estate as the Trustee reasonably determines are reasonable and appropriate from time to time to provide the medical care and standard of living to Grantor set forth hereafter in ARTICLE VII, taking into consideration any other resources readily available to the Grantor which are known to the Trustee. Wherever used in this - 2 - Paragraph "B", the term "Trustee" shall also include any Co-Trustee serving with the Grantor. C. Upon the death of the Grantor, the Trustee sha{I take whatever action is necessary to collect the proceeds of any insurance policies on the Grantor's life which are in the Trust Estate. to order to facilitate prompt collection of such sums, the Trustee shall furnish the necessary proof of death to the respective insurance companies and is authorized and empowered to do any and all things that in the Trustee's discretion are necessary to collect such proceeds, including, but not limited to, the power to execute and deliver releases, receipts, and ail other necessary papers. No insurance company which has issued a policy of insurance owned by this Trust shall be required to inquire into the terms of this Trust Agreement, nor to see that the policy proceeds are in fact applied or disposed of in accordance with the terms of this Trust. The receipt of the Trustee issued to any insurance company with respect to any policy shall be a complete release of such company from liability with respect to such policy and shall be binding upon all persons interested in the Trust. The Trustee is authorized to institute legal proceedings to collect the proceeds of the policies, provided that the Trustee may require, before instituting such proceedings, that the expenses, including legal fees, which such Trustee reasonably expects to incur in such action be advanced or guaranteed to the Trustee. The Trustee is also authorized to compromise and settle any claims arising in connection with the policies on any terms such Trustee considers satisfactory and the Trustee's decision shall be binding upon all persons interested in the Trust. The Trustee shall not be liable for any failure to collect the entire proceeds of any policy provided the Trustee has made a good faith and diligent attempt to do so. - 3 - ARTICLE !I A. Unless the Grantor has been determined to be incompetent pursuant to the provisions of ARTICLE XVlll hereafter, and so remains, the Grantor may, by a written instrument duly executed and witnessed during the Grantor`s life: 1. Add property to, or remove property from, this Trust; and 2. amend this Trust Agreement to change the beneficiaries, their respective shares, the plan of distribution, or any other provision; and 3. revoke this Trust in its entirety or any provision hereof, and add or substitute additional provisions hereto. B. The right to amend or revoke this Trust shall be personal to the Grantor, and may not be exercised by any representative, agent, conservator, or attorney-in-fact. No change which increases the duties or changes the compensation of any corporate Trustee shall be effective without the consent of the Trustee. ARTICLE III Upon the death of the Grantor, the Trustee shall pay the Grantor's funeral expenses, the reasonable expenses of any administration of the Grantor's estate, and any Federal or State estate, inheritance, succession, death or similar taxes payable by reason of the Grantor's death, together with any interest thereon or other addition thereto, without reimbursement from any beneficiary. Written statements by the Executor of such sums due and payable by the estate shall be sufficient evidence of their amount and propriety for the protection of the Trustee. All payments made by the Trustee hereunder shall be - 4 - made first from the Grantor's Residuary Trust Estate, as an expense of administration, without apportionment, except that any Federal or State estate, inheritance, succession, death or similar taxes payable pursuant to this Article Ili, and any interest thereon or addition thereto, shall be paid first from Trust "A". ARTICLE 1V A. Upon the death of the Grantor, the Trustee shall, after making any distributions pursuant to ARTICLE III hereof, distribute the following specific bequests {any bequest to a Beneficiary who does not survive the Grantor as hereafter provided shall lapse and become part of the Grantor's Residuary Trust Estate): 1. To the beneficiaries named in any Memorandum signed by the Grantor, designating recipients of specific items of tangible personal property, whether such Memorandum was executed before or after the date of this Instrument, any items of tangible personal property designated therein which are owned by the Trust, notwithstanding any other provision of this instrument. The provisions of such Memorandum shall be deemed to supersede any conflicting provisions of this Instrument, and shall be binding upon all of the beneficiaries of this Trust_ If the successor Trustee acting upon the death of the Grantor does not receive, or is otherwise not in possession of, the original Memorandum within sixty (60) days after the date of death of the Grantor, the Trustee may distribute the tangible personal property pursuant to the terms of this Instrument, without further liability or obligation with respect thereto. 2. If the Grantor's spouse survives the Grantor by thirty (30) days, to Trust "A" a sum equal to the dollar amount, if any, which can pass free of federal - 5 - estate tax by reason of the unified credit and the state death tax credit allowable to the Grantor's estate (the "credit shelter amount"), reduced by the aggregate of (i) all items includible in such estate for federal estate tax purposes which either are disposed of in previous Articles of this Agreement or by the Will of the Grantor or which pass outside of either Instrument, but only if such items do not qualify for the federal estate tax marital deduction or the federal estate tax charitable deduction, and (ii) the amount of any administration expenses claimed as income tax rather than estate tax deductions. For the purpose of computing the sum passing to the Trustee, the values of assets as finally determined for federal estate tax purposes shall be used. The Trustee then serving as Trustee under this Instrument shall likewise serve as Trustee of Trust "A" unless otherwise provided hereafter. 3. If the Grantor's spouse does not survive the Grantor, then to each of the following who is living, or in existence if an entity, on the date of death of the Grantor: NONE B. Upon the death of the Grantor, the Trustee shall, after making any distributions pursuant to ARTICLE III and pursuant to Paragraph "A" of this ARTICLE IV, distribute the remaining assets of the Trust, including undistributed income (herein referred to as the "Residuary Trust Estate"), as follows: 1. If the Grantor's spouse survives the Grantor by thirty (30) days, to the Grantor's spouse, free of trust; provided, however, if upon the death of the Grantor there shall exist a Trust of which the Grantor's spouse is the Grantor and a current income beneficiary, then this bequest shall be distributed to such Trust, subject to all of the terms and provisions thereof. - 6 - 2. If the Grantor's spouse does not survive the Grantor by thirty (30} days, to the Beneficiaries, and as provided, in Paragraph "F" of ARTICLE V hereof, subject to the provisions of Paragraph "G" of said ARTICLE V. ARTICLE V Trust "A" shall be held, administered and distributed as follows: A. The Trustee shall pay to or apply for the benefit of the Grantor's spouse, for such spouse's lifetime, all of the net income from Trust "A", in convenient installments but no less frequently than quarter-annually. Further, the Grantor's spouse shall be entitled to use any tangible personal property, and to live in any real property, owned by the Trust for as long as the Grantor's spouse may desire to do so, without charge and without liability except for gross negligence or intentional damage. To determine "net incomes, there shall be deducted from the gross income, in addition to other ordinary Trust expenses, all expenses of ownership and use applicable to such real property. B. {n addition, the Trustee shall also make payments of principal to the Grantor's spouse, or expend the same for the benefit of such spouse, in such amounts and at such times as the Trustee determines are reasonable and necessary to provide to the Grantor's spouse: (1}full, high quality medical care including, whenever reasonable and to the extent reasonably needed, private nurses and private care, and (2} maintenance and support in reasonable comfort. C. With respect to Paragraph "B" of this Article V, the Trustee shall give primary consideration to the needs (including, but not limited to, such financial obligations as debt repayment and income tax liability} and best interests of the Grantor's - 7 - spouse. Notwithstanding the foregoing, in making such determinations the Trustee shat{ take into account any other income and assets of the Grantor's spouse known to the Trustee. Notwithstanding Paragraph "B" of this Article V, with respect to any distribution of principal for the medical care of the Grantor's spouse, the Trustee is strictly prohibited from making any payments: (a) for medical car the cost of which is payable by any govemmenta! entity or pursuant to any governmental program of reimbursement or payment, or (b} in reimbursement to any government entity which may have incurred expense for the benefit of the Grantor's spouse pursuant to any governmental program of reimbursement or payment for medical care. D. The Grantor's spouse may at any time, by written notice, require the Trustee to make any nonproductive property of this Trust reasonably productive within a reasonable time. E. Upon the death of the Grantor's spouse, any undistributed income of the Trust shall be distributed to any Revocable Trust, existing on the date of death of the Grantor's spouse, of which such spouse was the Grantor and current income beneficiary or, if there is none, then to the estate of the Grantor's spouse. F. Upon the death of the survivor of the Grantor and the Grantor's spouse, the Trustee shalt divide the Residuary Trust Estate or the remaining Trust Principal, as appropriate, into equal separate shares so as to provide one (1 }share for each of the Grantor's children then {wing and one (1 } share for each of the Grantor's children then deceased who shalt leave issue then living, such issue to take their deceased parent's share by representation. Such shares shall be distributed to the beneficiaries thereof except as otherwise provided herein. - 8 - G. Notwithstanding the provisions of Paragraph F of this ARTICLE W, with respect to any Trust share allocated to MARY ANN SLATTERY, the Trustee shall hold such share, 1N TRUST, for the lifetime of the beneficiary, to be administered and distributed as follows: 1. Ali income shall be distributed to or for the benefit of the beneficiary not less frequently than quarter annually. The beneficiary may at any time, by written notice, require the Trustee to make any nonproductive Trust property reasonab{y productive within a reasonable time. 2. Principal of the Trust shall be distributed to or for the benefit of the beneficiary at such times, and in such amounts, as the Trustee, in such Trustee's discretion, shall determine to be reasonable and appropriate for the education, medical care, and support and maintenance in reasonable comfort of the beneficiary; provided, however, with respect to any distribution of principal for the medical care of the beneficiary, the Trustee is strictly prohibited from making any payments: (a} for medical car the cost of which is payable by any governmental entity or pursuant to any governmental program of reimbursement or payment, or (b) in reimbursement to any government entity which may have incurred expense for the benefit of the beneficiary pursuant to any governmental program of reimbursement or payment for medical care. 3. Upon the death of the beneficiary, the Trustees shall distribute the then remaining principal of the Trust share of such beneficiary, if any remains, to his or her then living issue by representation, or if such beneficiary has died leaving no such issue, then to the Grantor's then living issue, by representation, except that the share of any child or grandchild of the - 9 - Grantor for whose benefit a trust shall then exist hereunder shall be added to such trust, to be administered and disposed of as if a part thereof from inception. ARTfCLE VI In the administration of any property, real or personal, farming a part of this Revocable Trust, or any Trust subsequently established hereunder, the Trustee shall, in addition to and not by way of limitation of the powers provided by law, have the following powers, to be exercised in the Trustee`s sole discretion and without approval of any Court: 1. To retain, temporarily or permanently, any or all property received by the Trustee in the form in which it was received; to acquire by purchase, exchange or otherwise and retain, temporarily or permanently, any kind of realty or personalty, wherever located; to invest and reinvest in stocks (common or preferred) and bonds, without being limited to investments authorized by law, and in investment companies and mutual funds, ready asset funds, and legal and discretionary common trust funds (including investment companies and common trust funds maintained by any corporate Trustee or any affiliate thereof without the necessity of notice to beneficiaries); and to deposit funds in one or more savings or other banks (including any corporate Trustee or any affiliate thereof without the necessity of notice to beneficiaries} in any form of interest-bearing account or deposit; 2. To sell, exchange or otherwise dispose of real property and personalty, publicly or privately, for any purpose (including the distribution or division of the asset, reduction of carrying costs of the Trust, securing cash needed for other Trust purposes, or to protect against loss of value thereof), wholly or partly on credit and for any consideration deemed reasonable and appropriate by the Trustee; - 10 - 3. To vote (if a corporation, through officers, employees or agents of the Trustee), in person or by general, limited or discretionary proxy, in connection with any stocks or other securities constituting assets of any Trust hereunder; 4. To manage real property in such manner as the Trustee shall deem best, with authority - to lease the same or grant easements with respect thereto, to erect, after, repair or demolish buildings, to adjust boundaries, to dedicate streets or other ways for public use without compensation, to improve, repair, subdivide and vacate any of said property, to impose such easements, restrictions, conditions, stipulations and covenants as the Trustee may see fit, to insure the property (and improvements thereon and contents thereof} with casualty, liability and other insurance in such amounts as the Trustee deems reasonable, to retain persons to inspect, treat, clean, and maintain the property and any improvements thereon without liability for any neglect, omission, misconduct, or default of any such person provided the same was selected and retained with reasonable care, and to pay all expenses related to the use and%or ownership of such property. Upon request of the Grantor, or, if the Grantor is deceased or has been determined to be incompetent pursuant to the provisions of ARTICLE XVIII hereafter and so remains, then upon the request of the Grantor's spouse (unless such spouse has likewise been determined to be incompetent and so remains}, the Trustee shall sell any property which constitutes the personal residence of the Grantor or, upon the Grantor's death or residence in a nursing facility, of the Grantor's spouse, and purchase such substitute therefor of comparable or lower price, or lease such substitute therefor, as is likewise requested; 5. To determine, in the Trustee's so{e discretion, what shall be fairly and equitably charged or credited to income and what to principal, and in making that determination to emp{oy an accountant or attorney-in-law and to rely upon the opinion thereof; - 11 - 6. To make any payment or distribution directly to any beneficiary or to apply the same for such beneficiary's benefit; 7. To distribute principal and income in kind or in money, or partly in each, or by way of undivided inferests; 8. To renew, assign, alter, extend, compromise, release, with or without consideration, or submit to arbitration, obligations or claims, including taxes, held by or asserted against the Trust or which affect Trust assets; 9. if a corporation, to hold property in the Trustee's own name or in the name of nominees, or with respect to stock certificates to hold the same in the form of street certificates; 10. To borrow money, from the Trustee if a corporation, or from others, and pledge or mortgage any property, for the payment of estate taxes, debts, legacies or expenses, or for any purpose which the Trustee deems reasonable and appropriate to facilitate the administration of the Trust or to avoid the untimely sale of Trust assets; 11. To abandon, in any way, property which the Trustee determines is not worth protecting; 12. To collect, receive and receipt far rents, issues, profits, and income of the Trust Estate; to retain such reserves for trust expenses and liabilities as the Trustee deems reasonable and appropriate; 13. To insure the assets of the Trust Estate, including insurance against any damage or loss that may occur during delivery to beneficiaries; - 12 - 14. To employ and compensate agents, accountants, investment advisors, brokers, attorneys, tax specialists, Realtors, and other advisors deemed by the Trustee needful for the proper administration of the Trust Estate, and to do so without liability for any neglect, omission, misconduct, or default of any such agent or professional representative provided the same was selected and retained with reasonable care; 15. To hold and retain the principal of the Trust Estate undivided until actual division shat! become necessary in order to make distribution; to hold, manage, invest and account for the several shares or parts thereof by appropriate entries on the Trustee's books of account; and to allocate to each share or part of share its proportionate part of all receipts and expenses; provided, however, the carrying of several trusts as one shat! not defer the vesting in title or in possession of any share or part of any share thereof; 16. To continue to hold any stock, memberships, securities, notes or obligations of any closely held corporation or limited liability company which Grantor may own in whole or in part, and to cooperate fully in the management and operation of said corporation or limited liability company; to sell, collect, or otherwise {iquidate such stock, memberships, securities, notes or obligations if deemed advisable, for such amounts and upon such terms as the Trustee deems reasonable and appropriate; 17. To sell Trust assets to the current income beneficiary upon such terms as the Trustee deems reasonable and appropriate; 18. In the event that Co-Trustees shall be serving hereunder, all decisions shall be made with the unanimous approval of the Co-Trustees; provided, however, whenever the Grantor is serving as Ca-Trustee, either Co-Trustee may act alone; provided further, however, if the Grantor's spouse is serving as Co-Trustee of Trust - 13 - "A", any discretion to be exercised by the Co-Trustees of Trust ~A" shall be exercised solely by the remaining Co-Trustee. The provisions of this Paragraph shall not limit the right of any Co-Trustee to authorize another Co-Trustee to execute documents on his or her behaifi pursuant to a Power of Attorney. 19. In the Trustee's discretion, to make gifts on behalf of the Grantor to the Grantor's children, grandchildren, or to any charity or church, giving due consideration to the financial needs of the Grantor and the recipient known to the Trustee and further limited as to each gift to the amount of the Federal Gift Tax Exclusion for such year. 20. In general, to exercise alt powers in the management of the Trust Estate of this Revocable Trust or any Trust subsequently established hereunder which any individual could or would exercise in his own right, in the reasonable and prudent management of his own property, upon such terms and conditions as the Trustee may deem best, and to do all acts, and execute all documents, which the Trustee may deem necessary or proper to carry out the purposes of this Trust Agreement. ARTICLE Vli Any Trustee of this Revocable Trust (except the Grantor), in distributing principal, exercising discretion, determining reasonableness and need, deciding whether or not to exercise authority granted herein, or considering investment of Trust assets, shall be obligated to give primary consideration to the needs and best interests of the Grantor, including the providing of fuii, high quality medical care including, whenever reasonable and to the extent reasonably needed, private nurses and private care sufficient to provide the Grantor with peace of mind and adequate personal attention and, to the extent possible, taking into consideration the total assets of the Trust and the health and life - 14 - expectancy of the Grantor, to the providing of support in reasonable comfort, that is, a standard of living comparable to that enjoyed by the Grantor on the date hereof. ARTICLE Vlll In no case shall any person dealing with a Trustee of this Revocable Trust or of any Trust created pursuant to this Instrument, in relation to any part of the Trust Estate, be obliged to see to the application of any money or other property paid or delivered to the Trustee thereof, or be obliged to see that the terms of any such Trust have been complied with. No such person shat{ be required, and no person not a beneficiary or not acting for a beneficiary shall be entitled, to inquire into the necessity or expediency of any act of a Trustee. The performance by the Trustee then serving of any act, or the execution by any such Trustee of any instrument, in relation to the Trust Estate of such Trust shall be conclusive evidence in favor of any person dealing with such Trustee that the Trustee had the power and authority to perform such act or to execute such instrument. A written statement of a Trustee at any time as to any fact relative to the Trust may also be relied upon and shall also be conclusive evidence in favor of any transfer agent and any other person dealing in good faith with the Trustee in reliance upon such statement_ ARTICLE IX The rights, powers, authority, duties and obligations established by this Instrument sha11 apply to the Initial Trustee and to all successor Trustees. No bond shall be required of any Trustee for the faithful performance of the duties hereunder. Any successor to the trust business of any corporate fiduciary designated herein or acting hereunder shall succeed to the capacity of its predecessor without conveyance or transfer. Any Trustee serving hereunder shall be entitled to reimbursement of expenses reasonably incurred and reasonable compensation for services rendered (if a corporation, in - 15 - accordance with its standard fee schedule in effect at the time that such services are rendered or, if none, then the compensation shall be as provided by South Carolina law). No Trustee sha{I be responsible or liable for the actions or accounts of any previous Trustee, or of the Executor of the Grantor's estate. Unless requested in writing by a beneficiary, no Trustee shall be obligated to inquire into such acts or omissions or to ascertain that the property transferred to such Trustee is the entire trust property. No Trustee shall be liable for the exercise of any powers or discretion unless such exercise shall be made in bad faith or shall constitute gross negligence, unless otherwise specifically provided herein. ARTICLE X No interest in principal or income payable, or to become payable, to any beneficiary of any Trust created by this Instrument shall be subject to anticipation, assignment, pledge, sale or transfer in any manner. No beneficiary shall have the power to anticipate or encumber such interest. No such interest, while in the possession of the Trustee, shall be liable for, or subject to, the debts, contracts, obligations, liabilities or torts of any beneficiary. ARTICLE Xt Ail questions pertaining to the validity, construction or administration of any Trust created by this instrument shall be determined in accordance with the laws of the State of South Carolina_ - 16 - ARTICLE Xlf A_ Any Trustee may resign at any time by executing a Resignation Declaration in form recordable in the Office of the RMC for Beaufort County, South Carolina, and immediately delivering the original executed document to the current income beneficiary {or, if the Trustee is the Grantor, then to the Successor Trustee), or to the legal guardian or attorney-in-fact thereof. The Grantor and any individual Trustee or Co-Trustee may resign immediately; the resignation of any Corporate Trustee or Co-Trustee shall become effective on the thirtieth (30th) day following the date of execution of the Resignation Declaration unless otherwise approved by the current income beneficiary. The Resignation Declaration shall clearly identify and reference this Trust Agreement, shall clearly identify the resigning Trustee, and, in the case of the Grantor or an individual Trustee or Co-Trustee, set forth the effective date of the resignation. The execution and delivery of the Resignation Declaration may be undertaken by an Attorney-in-Fact of a resigning Trustee, and any such execution and delivery of documents shall be binding upon the resigning Trustee (subject to Paragraph E of this Article as to the Grantor). Any resigning Trustee shall be obligated to use best efforts to facilitate the transfer of assets and Trust records and shall promptly prepare and deliver a final accounting. B. At such time as the Grantor shall resign as Trustee, or sooner be determined to be incompetent pursuant to the provisions of ARTICLE XVIII hereafter, LEONARD C. BELLANCA sha{I commence serving as Successor Co-Trustee hereunder or, if LEONARD BELLANCA is not then serving, then LEONARD C. BELLANCA shall commence serving as the sole Successor Trustee hereunder. Upon the death of the Grantor, LEONARD C. BELLANCA shall serve as sole Trustee hereunder. If the designated Successor Trustee shall be unable or unwilling to serve or to continue to serve in such capacity, the following shall serve as Successor thereto, - 17 - as long as they are willing and able to do so, in the order of succession designated, it being the intention of the Grantor to fill vacancies as they arise: first -JAMES A. BELLANCA; second -JOSEPH J. BELLANCA; third -PAUL M. BELLANCA. C. If all of the foregoing Trustees andfor Co-Trustees shall be unwilling or unable to serve or continue to serve in such capacity, the Grantor, or if the Grantor is deceased or incompetent as aforesaid, then the Grantor`s spouse or, if such spouse is deceased or incompetent as aforesaid then the eldest child of the Grantor then living and competent, shall promptly appoint a successor Trustee which is a trust company or a financial institution possessing a trust department or a trust company subsidiary of a securities brokerage company (except that the Grantor may appoint any person or entity whomsoever). D_ A Successor Trustee shall, prior to commencing service as a Successor Trustee, execute a Confirmation of Successor Trustee and record the same in the Office of the RMC for Beaufort County, South Carolina, to which shall be attached the Resignation Declaration of the preceding Trustee. Such Confirmation of Successor Trustee shall contain an accurate identification of the Trustee, the Trustee's address, telephone number and fax number as applicable, and the date upon which the Successor Trustee sha{{ commence serving in such capacity; the Instrument shall also clearly identify and reference this Trust Agreement and shall include an acceptance by the Trustee of the obligations established hereunder. E. If the Grantor has ceased to serve as Trustee but is still living, the Grantor may thereafter commence re-serving as Trustee by delivering written notice of termination to the current Trustee, which notice shall clearly identify and reference this Trust Agreement and the effective date that the Grantor shall recommence serving as Trustee, and also recording the same in the Office of the RMC for - 18 - obligated to promptly notify the next succeeding beneficiary of income or principal as to the name and address of the new Trustee. ARTICLE XIV With respect to any tangible persona{ property owned by the Trust, the Grantor's spouse shall be entitled to possession thereof fior as long as such spouse desires, and during such possession (a) the Grantor's spouse shall be responsible for the care, maintenance, and repair of such property, and all expenses applicable to the ownership or use thereof, (b) the Grantor's spouse shall have no liability with respect to such property except for intentional damage or destruction or conveyance, with or without consideration, to any person other than the Trustee hereof, and (c} the Trustee shall possess no liability whatsoever with respect to such property. When such property is returned to the custody of the Trustee the Trustee shall distribute the same by dividing such property in as nearly equal shares a may be practical so as to provide one share for each child of the Grantor then living and one share for each child of the Grantor who, being deceased, has left children then living, such children to be al{ocated their deceased parent's share in as nearly equal shares as may be practical. The Trustee shall give due consideration to any preferences expressed by the Grantor's children and grandchildren to the extent reasonably possible; the discretion exercised by the Trustee in connection therewith shall be exclusive and absolute, and no decision made by the Trustee may be challenged by any beneficiary hereunder. As to any beneficiary under the age of 21 years, the Trustee may, in the Trustee's sole discretion, sell the property allocable to such beneficiary (including to other beneficiaries} and distribute the sale proceeds to the beneficiary in lieu thereof. - 20 - ARTICLE XV The Grantor's spouse is specifically authorized to disclaim all, or any part, of any bequest made to said spouse by delivery of a written Instrument setting forth such disclaimer in such manner as is necessary to qualify the same as a "qualified disclaimer" under Section 2518 of the Internal Revenue Cade of 1986, as amended, or any successor to such Section; in such event, the assets so disclaimed shall be distributed as if the Grantor's spouse did not survive the Grantor and said spouse shall possess no right to restrict, influence or place any condition upon such distribution. ARTICLE XVI Whenever the word "Trustee", or any modifying or substitute pronoun thereof, is used in this Instrument, such word or pronoun shall (1) refer to the person or entity then properly serving, or authorized to serve, in such fiduciary capacity pursuant to the provisions of this Agreement, (2} be held and taken to include both the singular and plural, and the masculine, feminine, and neuter gender thereof, as appropriate, and (3) apply equally to any Trustee{s} herein named, to any Trustee(s) hereafter designated as permitted by this Agreement, and to any successor thereof. ARTICLE XVII If any share hereunder shall vest in absolute ownership in a beneficiary who has not then attained the age of twenty-one (21) years, the Trustee is authorized and empowered, in the Trustee's uncontrolled discretion, to hold the share so vested in such person, or any part thereof, in a separate Trust for the benefit of such person, notwithstanding that such share may consist of investments not authorized by law for trust funds. During the term of such Trust, the Trustee shalt apply all or such part of the - 21 - income, and principal as necessary, as the Trustee shall determine to be reasonably needed for the support, maintenance, medical care, and education of such beneficiary, taking into account to the extent the Trustee deems appropriate the resources of the beneficiary's parent(s). Any undistributed income shall be accumulated. At such time as the beneficiary shall attain the age of twenty-one (21) years, or sooner die, the Trustee shall pay over the principal and any accumulated income thereof to the beneficiary or to his or her estate, as applicable. The authority conferred upon the Trustee by this ARTICLE XVII shall be construed as a power only, and shall not operate to suspend the absolute vesting of ownership in such beneficiary. With respect to the administration of such Trust, the Trustee shall have all of the powers vested in the Trustee, and all of the obligations established with respect to a Trust beneficiary, under the provisions of this Agreement. If pursuant to any Trust created hereunder, income or principal shalt become distributable to a person under the age of 21 years, or to a person under legal disability, or to a person not adjudicated incompetent but who, by reason of illness or mental or physical disability, may, in the opinion of the Trustee, be unable properly to administer such amounts, then the same, or any portion thereof, may, in the discretion of the Trustee, be applied for the benefit of the beneficiary and/or a11, or the remaining portion thereof, shall be distributed by the Trustee in one or more of the following ways, as the Trustee deems best: (1) Directly to such beneficiary; or (2) To the parent(s) or legally appointed guardian of such beneficiary. - 22 - ARTICLE XVIII In the event that the Grantor is determined to be incompetent, the Grantor shall cease to serve as Trustee under this Agreement. If two physicians, one of which is the regular physician of the Grantor, declare in writing that the Grantor is unable to undertake most financial affairs (investments, gifts, purchases, sales, payment of bills, incurring of expenses, etc.) in a competent manner, or is unable to protect financial assets to meet future needs, the Grantor shall be deemed to have been determined to be incompetent for the purposes of this Agreement. The term "regular physician of the Grantor" shall refer to any physician who has treated the Grantor, and/or examined the Grantor's health, at least three (3) times during a period of time which begins no more than two (2) years before the determination of incompetency and, in addition, has examined the Grantor's mental and/or physical health, as appropriate (or secured competent examination thereof}, within thirty (30} days prior to such determination of incompetency. Notwithstanding the foregoing, any judicial determination of incompetency, or of competency, shall supersede any determination hereunder rnade within one (1) year before or after such judicial determination. The foregoing provisions shall likewise apply to any individual who is serving, or is to serve, as Trustee or Co-Trustee hereunder, if any. ARTICLE XIX Every Trustee (except the Initial Trustee} shall maintain accurate accounts and records and sha{I prepare an account of the administration of the Trust not less frequently than annually and render the account to each person entitled to receive Trust income during the period of the account and each person who would be entitled to distribution of principal if the Trust had terminated on such date. Such statement shall set forth a complete inventory of the property then constituting the Trust Estate and shall reflect all receipts and disbursements of income and principal of the Trust Estate. The - 23 - assent by ail persons so entitled to receive the account shall make such account, in the absence of fraud or manifest error, binding and conclusive upon all persons then having, or who may thereafter have, any interest, vested or contingent, in the income or principal of the Trust Estate: The failure of any such person (1) personally or (2) by his or her attorney-in-facf, or (3} if a minor by his or her parent or legal guardian, or (4) if under disability by his or her legal guardian or conservator, or (5) if deceased by his or her personal representative, to mail a written objection to any such account within sixty (60) days after receipt thereof shall be deemed to be an assent by such person. ARTICLE XX Notwithstanding any other provision hereof, in the event any Trust held hereunder shall, in the opinion of the Trustee, become uneconomic or otherwise inadvisable to administer as a Trust, the Trustee, in the Trustee's absolute discretion, is authorized to terminate such Trust and distribute the remaining principal to or for the benefit of the beneficiaries then entitled or eligible to receive the income and in the same proportion. In such event, no remainder beneficiary shall possess any claim against the income beneficiary or the Trustee. ARTICLE XXI Notwithstanding anything set forth in this Instrument to the contrary, all Trusts created hereunder shall terminate no later than twenty-one (21) years after the death of the last survivor of the Grantor's spouse, children and grandchildren living on the date of the Grantor's death, at which time the Trustee shall distribute the remaining principal to or for the benefit of the beneficiaries then entitled or eligible to receive the income therefrom. - 24 - IN WITNESS WHEREOF, the Grantor and the initial Co-Trustees have set their hands and seals to this Trust Agreement on the date first set forth above. IN THE PRESENCE OF: GRANTO -MARY G. BELLANCA ~ ~ ~~~ . INITIAL CO ~%, RUSTEE -MARY G. BELLANCA `~,~ f~> i l ~~ , "" ~~fN y / V INITIAL CO-TRUSTEE -LEONARD BELLANCA STATE OF SOUTH CAF~tOLINA ) COUNTY OF BEAUFORT ) PROBATE Grantor, Initial Co-Trustee PERSONALLY appeared before me the undersigned witness who, under oath, says that (s)he saw the within named Grantor and Initial Co-Trustee, MARY G. BELLANCA, sign, seal, and as her act and deed, deliver the within Trust Agreement, and that (s)he with the other witness subscribed above witnessed the execution thereof. ~~~ Q~ (Witness} SWORN to before me this 15~' day of April, '997. , ~~~ Notary P lic for`South C~rolin My Commission Expires:% ~ `.~`~ - 26 - r \~ /, r ,~ ~~ STATE OF SOUTH CAROLINA COUNTY OF BEAUFORT PROBATE Initial Co-Trustee PERSONALLY appeared before me the undersigned witness who, under oath, says that (s)he saw the within named Initial Co-Trustee, LEONARD BELLANCA, sign, seal, and as his act and deed, deliver the within Trust Agreement, and that (s)he with the other witness subscribed above witnessed the execution thereof. (~ Witness} SWORN to before me this 15th day of Aprii},1997. ~.. ~ f~` Notary Public fo South aro i My Commission Expires ~~ ~'~' C:tdata\W P~ATA\PETER\BALI.MICA\TRUST.SHE.wpd - 27 - ~,~ BAST iN~LL l-~ND TESTAMENT \`"~ ~_ OF MARY G. BELLANCA (, MARY G. BELLANCA, currently a resident of and domiciled in the Town of Hilton Head Island, County of Beaufort, State of South Carolina, do hereby make, publish and declare this to be my Last Will and Testament. ARTICLE 1 I am married to LEONARD BELLANCA, who is referred to in this Instrument as my "spouse." LEONARD C. BELLANCA, of Mechanicsburg, Pennsylvania, JAMES A. BELLANCA, of Winnetka, Illinois, JOSEPH J. BELLANCA, of Malvern, Pennsylvania, PAUL M. BELLANCA, of Honolulu, Hawaii, and MARY ANN SLATTERY, of Midliothian, Virginia, together with any children whom i may adopt after my execution of this Instrument, are referred to in this Instrument as my children, and no other individual, regardless of relationship to me, shall be entitled to share in any bequest or devise made to my children, or to any of them. It is my wish that, upon my death, I be cremated and my ashes disposed of as determined by my Executor. ARTICLE ll I revoke all Wills and Codicils previously made by me. I direct that my just debts (as determined by my Executor), the expenses of my last illness and funeral, and the expenses of the administration of my estate be paid as soon as practicable after my death from my residuary estate. If at the time of my death any real property herein bequeathed is subject to a mortgage, 1 direct that the beneficiary receiving the mortgaged property shall - 2 - ~ Lr ~-~ . ~~ ,_, . take it subject to the mortgage and the indebtedness secured thereby and shalt not be entitled to have such indebtedness paid out of my general estate. I direct that all estate, inheritance, or other taxes assessed upon or with respect to any property or interest in properly included in my estate for such tax purposes shall be paid as provided in the Trust referenced in, or created pursuant to, Article V of this Instrument. ARTICLE III i direct that, to the extent permitted by the Probate Code of South Carolina, my Executor, Beneficiaries and Heirs abide by any Memorandum, signed by me, designating the recipients of specific items of tangible personal property which t awn at the time of my death, whether such Memorandum is executed before or after the date of this Instrument. I further direct that, if any named recipient shall not survive me, the bequest to that recipient shall be deemed to have lapsed, and the items of tangible personal property designated for such recipient shall, unless otherwise provided in the '~ Memorandum, become part of my remaining tangible personal property bequeathed by this Instrument. ARTICLE IV I hereby bequeath all of my tangible personal property (except currency) not otherwise bequeathed by separate Memorandum to beneficiaries who have survived me, including but not limited to furniture, furnishings, collections, antiques, paintings, silverware, china, glass, books, jewelry, wearing apparel, automobiles, boats, and all insurance policies thereon, to my spouse if my said spouse survives me by thirty (30) days. If my said spouse does not so survive me, I bequeath all of said tangible persona! property to my children who survive me, to be divided among them by my Executor in as nearly equal shares as may be practical. 1 request, but do not require, that my Executor give due regard to any preferences expressed by my children; the discretion of my Executor shat! - 2 - be exclusive and absolute, and no decision made by my Executor may be challenged by any beneficiary hereunder. The cost of storing and insuring any of my tangible personal property shall be an administrative expense payable from my residuary estate; costs of delivery shall be borne by the beneficiary receiving the same. ARTICLE V I bequeath the remainder of my property, real and personal, tangible and intangible, of whatever nature and wherever it may be located, whether acquired before or after the execution of this Instrument, including any specific devise or bequest established by this instrument which lapses (referred to in total as my "residuary estate") to the then Trustee or Trustees under that certain Trust Agreement executed by me as Grantor prior to the execution of this Instrument and dated the 15"' day of April, 1997. The Trustee or Trustees shall add the property bequeathed and devised by this Article to the corpus of the above described Trust and shall hold, administer and distribute said property in accordance with the provisions of the said Trust Agreement, including all amendments thereto. In the event that, for any reason, the bequest and devise under this Article is ineffective and invalid, then 1 bequeath the same to my eldest son, LEONARD C. BELLANCA as Trustee, to be held, administered and distributed in accordance with the provisions of the above described Trust Agreement, which provisions are incorporated by this reference and made a part of this Instrument to the same extent as if set forth in their entirety in this Instrument. If for any reason such person or entity is unable or unwilling to serve as Trustee, I hereby nominate, constitute and appoint as successor or substitute Trustee that person or entity which is next designated in ARTICLE XII of the above referenced Trust Agreement that is willing and able to so serve; if there be none, then I appoint that trust company, financial institution possessing a trust department or trust company subsidiary of a securities brokerage company designated in a written instrument filed with the court having jurisdiction over this Will and signed by my spouse, or, if my - 3 - spouse fails to act in a timely manner, signed by or on behalf of my oldest living child, or if he or she fails to act in a timely manner, by the court having jurisdiction of the probate of my estate. I hereby refrain from exercising any power of appointment that I may have had at the time of my death. ARTICLE VI I hereby nominate my husband, LEONARD BELLANCA as Executor of this my Will. If for any reason such nominee is unable or unwilling to serve or to continue to serve in such capacity, I nominate my eldest son, LEONARD C. BELLANCA as alternate or successor Executor. I direct that no person nominated as Executor hereunder shall be required to post any bond or other security for the faithful performance of such duties. My Executor shall receive reimbursement of all expenses reasonably incurred to undertake the duties of Executor. My Executor is specifically authorized and empowered to exercise all of the powers in the management of my Estate which any individual could exercise in the management of similar property owned in his own right, upon such terms and conditions as to my Executor may deem best, and to execute and deliver any and all instruments and to do all acts which my Executor may deem proper or necessary to carry out the purposes of this my Will, without the necessity of a court order. My Executor is specifically authorized to sell real property and personal property, regardless of value, without court approval whenever the Executor, in his or her sole discretion, determines that such sale will facilitate distribution of the estate, prevent loss of value, or otherwise be in the best interests of the beneficiaries. IN WITNESS WHEREOF, 1, MARY G. BELLANCA, sign my name to this Instrument consisting of 5 typewritten pages (the following page included} this 15~' day of - 4 - ., ~,y~_~, April, 1997, and being first duly sworn, do hereby declare to the undersigned authority that I sign this Instrument as my Last Will and Testament and that I sign it willingly, that I execute it as my free and voluntary act for the purposes therein expressed, and that 1 am eighteen years of age or older, of sound mind, and under no constraint or undue influence. MARY G. BELLANCA, Testatrix We, Vet t C,~(~ ~:~P 1, r~c(~ and ~,~ ~ . V v b~ ,the witnesses, sign our names to this Instrument and at least one of us, being first duly sworn, does hereby declare, generally and to the undersigned authority, that the above Testatrix signed and executed this Instrument as the Last Wili and Testament of said Testatrix, and that said Testatrix signed it willingly, and that each of us, in the presence and hearing of the Testatrix, hereby signs this Will as witness to the execution hereof by the Testatrix, and that to the best of our knowledge the Testatrix is eighteen years of age or older, of sound mi ,and nde~r no constraint or undue influence. re rd ng a -~'~ itn s residing at cS (Witness) STATE OF SOUTH CAROLINA ACKNOWLEDGMENT COUNTY OF BEAUFORT Subscribed, sworn to and acknowledged before me by MARY G. B LL . CA, t e Testatrix, and subscribed and sworn to before me by I { Lf , a witness, this ~ day of ~-t'K/~1 t...._~ , 1997. (SEAL) Notary Pu lic for Sout Carolina My Commission Expires: ~ C~~ C:ldatatWPDATA1PEfER16Al[AtJCAtWIl.t.9iE,wpd - 5 - Beaufort County, South Carolina. If the Grantor was determined to be incompetent pursuant to the provisions of ARTICLE XVIII hereafter, the Grantor must first be determined to be competent in the same manner, in which event the notice must also be executed by finro physicians who, by their execution, are approving the action undertaken by the Grantor pursuant to such notice. The notice must be signed by the Grantor, and may not be executed by any representative, agent, conservator, or Attorney-in-Fact of the Grantor. ARTICLE XIU Notwithstanding the provisions of ARTICLE X11, the current income beneficiary (or a majority thereof if more than one) of any Trust created hereunder, personally or, if a minor or under disability, by attorney-in-fact, shall have the absolute right at any time to discharge any Trustee or Co-Trustee of such Trust, without cause, provided that such current income beneficiary (or a majority thereof if more than one) promptly appoints as successor Trustee the next succeeding Trustee or Co-Trustee designated by the Grantor in ARTICLE Xlt hereof or, if there be none, then a trust company or a financial institution possessing a trust department or a trust company subsidiary of a securities brokerage company. However, the Grantor may appoint any person or entity whomever to serve as successor Trustee. The income beneficiary (or majority thereof if more than one) shall deliver to the current Trustee written notice of Termination, which notice shall clearly identify and reference this Trust Agreement, clearly identify the terminated Trustee, and set forth the effective date of the termination. The Successor Trustee shall execute and record with the RMC for Beaufort County, South Carolina, a Confirmation of Successor Trustee, to which there shall be attached a copy of the notice delivered to the terminated Trustee or Co-Trustee. The current Trustee shall be obligated to use best efforts to facilitate the transfer of assets and Trust records and shat( promptly prepare and deliver a final accounting. The current income beneficiary shall be - Z9 - ARTICLE XXII In the event that it cannot be readily determined whether or not a beneficiary named hereunder has survived the Grantor, it shall be presumed that the beneficiary did not survive the Grantor for purposes of this Agreement. ARTICLE XXIII Notwithstanding anything else to the contrary hereinabove, the Grantor's spouse may not undertake any action, individually or in the capacity of Co-Trustee, which would result in the inclusion of the assets of Trust "A" in such spouse's estate. This Article shall not limit the right of the Grantor's spouse to make any available election upon the Grantor's death. ARTICLE XXlV It is the intention of the Grantor (1) that this Instrument not be deemed to be, or treated as, the Last Will and Testament of the Grantor, (2) that no Probate of this Instrument be required or undertaken, and {3} that the assets, the title to which are held in the name of the Trust or in the name of the Trustee as Trustee (whether or not such title is publicly recorded}, shall not be treated as assets of the Estate of the Grantor or made subject to Probate. - 25 -