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Stock in Avonictech,Inc

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Stock in Avonictech,Inc.is a major asset of a split-interest trust.The trust is comprised of a single income beneficiary,who is the grantor's husband,and three grandchildren,who collectively constitute the principal beneficiaries (remaindermen) of the split-interest trust.The stock was worth $5 million at the time the trust was created,and the stock recently was sold for $17 million.The trust does not recite how gains on the sale of assets should be allocated.The $12 million gain on sale should be allocated:


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