The trustees of The Esther Eberstadt Baldwin Trust — 1974 commenced this action in the Probate and Family Court seeking reformation of the trust to authorize division of the trust into two subtrusts in order to minimize Federal generation skipping transfer (GST) taxes. The defendants are certain named beneficiaries, who have all assented to the proposed reformation, as well as the Commissioner of Internal Revenue, who has neither appeared nor participated in the case...
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