In re the Estate of Case

OPINION OF THE COURT

Renee R. Roth, S.

In this novel reformation proceeding commenced by the executors of the estate of Thomas C. Case, the object is to minimize the estate tax, not in decedent’s own estate but instead in the estate of his widow, Carolyn Case, upon her death.

Mr. Case’s will creates two trusts. One is a preresiduary credit shelter trust; the other is a residuary qualified terminable interest property (QTIP) trust. The provisions of both *700trusts are the same. The net income is payable to Mrs. Case for life and, upon her death, the remainder interest in each trust is payable one…