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New Jersey Supreme Court Finds County Board's Itemized Phone Bills are Not Public Records

2055(e)(2) as a charitable annuity remainder trust. The court held that Johnson's trust could not be reformed to meet one of the Section 2055(e)(2) exceptions while still complying with the terms of the will. Even though a contract could have been bought to satisfy the family grave maintenance, no upward limit existed on the amount required to support Johnson's remaining sister due to the unpredictable costs of medical care. Therefore, the amount of funds needed to fulfill the noncharitable bequests could not be accurately assessed until after all of Johnson's sisters had passed away. As a result, the funds to the charitable beneficiaries could only be assessed after all the sisters were deceased. Lastly, the Fifth Circuit held that the statutory language of the Internal Revenue Code was clear, and no express Congressional intent supported an exception in this case. Jersey held that the state's Right-to-Know statute did not create an unqualified right of access to a public body's itemized telephone billing records that disclosed the identity of the parties called. Furthermore , the telephone bills were not accessible under New Jersey common law because the public's need for the identity of the parties called did not outweigh the governmental policies of confidentiality in telephone communications and executive privilege.