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the Substituted Property by the Settlor, the Settlor paid New York State and City sales tax with respect to the Substituted Property. Following the Exchange, the Trustees may allow Trust beneficiaries to use the Substituted Property without charge or other consideration. EFTA_R1_01946806 EFTA02672769
st") pursuant to a trust agreement (the "Trust Agreement") between the Trustees and the Settlor. The Senior is deemed to own the Trust property for Federal and New York State income tax purposes, as provided in Sections 671 to 679 of the Internal Revenue Code. Under the terms of the Trust Agreement, the Senior has the ri
initigiauchandshe Substilittcd.nopestay, the SqL.121,.titsjaular paid New.York-Stotea saleswc with respectlethe Substituted Property. Bellowing the Exchange, the Trustees may allow Trust bealsiacies to t.4,,se the Substituted Propertrivithout chirtess oherconsiderattertrAc•• ' Applicable Law and Regul
uant to a trust agreement (the "Trust Agreement") between the Trustees and the Senior. A 1 1,44 The Senior is deemed to own the Trust property for Federal and New York State "4 • income tax purposes, as provided in Sections 671 to 679 of the Internal Rev 14/ Code. Under the terms of the Trust Agreement, the Senior has
initigiauchandshe Substilittcd.nopestay, the SqL.121,.titsjaular paid New.York-Stotea saleswc with respectlethe Substituted Property. Bellowing the Exchange, the Trustees may allow Trust bealsiacies to t.4,,se the Substituted Propertrivithout chirtess oherconsiderattertrAc•• ' Applicable Law and Regul
uant to a trust agreement (the "Trust Agreement") between the Trustees and the Senior. A 1 1,44 The Senior is deemed to own the Trust property for Federal and New York State "4 • income tax purposes, as provided in Sections 671 to 679 of the Internal Rev 14/ Code. Under the terms of the Trust Agreement, the Senior has
Entities connected to both Exchange and Federal and New York State

Samantha Power
PERSONLeon Black
PERSONthe State of New York
LOCATION
New York City
LOCATIONMartin Weinberg
PERSON
New York State
LOCATIONSettlor
ORGANIZATIONthe Trust Fund of any Trust
ORGANIZATIONthe "Substituted Property
ORGANIZATIONRichman
PERSONDepartment of Taxation and Finance
ORGANIZATIONReacquisition of Trust Assets
ORGANIZATIONBrookhaven
LOCATIONN.Y.2d 458
ORGANIZATIONSubstitution Power
ORGANIZATION
Apollo Global Management
ORGANIZATIONMcGraw-Hill, Inc.
ORGANIZATIONToscano
ORGANIZATIONExchmgell
ORGANIZATIONSqL.121,.titsjaular
ORGANIZATION