In re the Estate of Nossiter

OPINION OF THE COURT

Renee R. Roth, S.

This application seeks to construe and reform the will of Murray P. Nossiter by splitting a single qualified terminable interest property (QTIP) trust into three trusts so as to obtain the maximum benefit of the $1,000,000 generation-skipping transfer tax exemptions (GST exemption) of decedent and his surviving spouse. Several of petitioner’s objectives have been discussed by this court in previous decisions (Matter of Choate, 141 Misc 2d 489; Matter of Kaskel, 146 Misc 2d 278). One however is new, namely, that as part of the severance, petitioner seeks to…