MEMORANDUM
RAMBO, District Judge.
The history of the case sub judice is as follows:
On July 27, 1971, John C. Kunkel (hereinafter Decedent), testator of the estate of which plaintiffs are trustees, died. Decedent bequeathed fifty percent of his adjusted gross estate to a marital trust, which provided for the income to be paid to his wife and invasion of the corpus on her behalf if necessary, and created two powers of appointment over the corpus...
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