Seegel v. Miller

The gravamen of this case is whether, in funding a testamentary marital trust for his wife, Leonard I. Miller (Leonard) “intended that his estate take advantage of the maximum marital deduction allowable under the Federal *1008estate tax law,” Putnam v. Putnam, 366 Mass. 261, 262 (1974), while minimizing the amount of estate taxes due. As in the Putnam case, if we conclude that Leonard had such an intent, we must reconcile that intent with “a provision in his will [and provisions in the marital trust] which . . . places the burden on the marital trust to satisfy” tax obligations attributable to…