unt of shares to this trust in a manner similar to what Edward had done under the Final Decree. Sumner, like Edward, never filed a gift tax return. O'Connor Litigation At Edward's death, the IRS received his 706 filing and Googled his name. The result of the Google was the discovery of the O'Connor litigation.11 I

nt of shares to this trust in a manner similar to what Edward had done under the Final Decree. Sumner, like Edward, never filed a gift tax return. O'Connor Litigation At Edward's death, the IRS received his 706 filing and Googled his name. The result of the Google was the discovery of the O'Connor litigation.1 In