Illinois Appellate Court
Civil Court
Adoption
Court found testator's step-son to be a descendant for purposes of distribution under two trusts. Testator had adopted step-son when he was 22, 12 years after testator had married his father. Testator died 15 years later. Record fails to demonstrate his adoption occurred solely for purpose of taking under the trusts. Thus, the limited-use subterfuge exception does not preclude step-son from taking under tyhe trusts.(HOLDER WHITE and POPE, concurring.)