FACTS AND PROCEDURAL HISTORY
Robert Daniels died on March 25, 1982. The second amendment to the Robert and Isabelle Daniels Living Trust of 1982 established a qualified terminable interest property (QTIP) trust which gave Isabelle, as surviving spouse, the income for life and a limited power of appointment over the remainder.
Isabelle died on April 6, 1984. She had received $242...
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