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nd New York State income tax purposes, as provided in Sections 671 to 679 of the Internal Reyenue Code. Under the terms of the Trust Agreement, the Settlor has the fight to aequirei 44-14 or-reequire trust property at any time (the "Substitution Power"). The provision of the Trust Agree_merusleating th
ust") 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 Reyenue Code. Under the terms of the Trust Agreement, the Settlor has the f
") created an in-evocable trust (the "Trust- ) pursuant to a trust agreement (the "Trust Agreement") between the Trustees and the Settlor. A) ; The Settlor is deemed to own the Trust property for Federal and New York State 7-- - income tax purposes, as provided in Sections 671 to 679 of the Internal Re
ursuant to a trust agreement (the "Trust Agreement") between the Trustees and the Settlor. A) ; The Settlor is deemed to own the Trust property for Federal and New York State 7-- - income tax purposes, as provided in Sections 671 to 679 of the Internal Revenne J t 444 Code. Under the terms of the Trust Agreement, the S
"Substitution Power"). The provision of the Trust Agreement creating the Substitution Power reads as follows: "Reacquisition of Trust Assets. The Settlor at any time or from time to time may acquire or reacquire any portion of the Trust Fund of any Trust by substituting therefor other property of an
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
Settlor") created an irrevocable trust (the "Trust") pursuant to a trust agreement (the "Trust Agreement") between the Trustees and the Settlor. The Settlor 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
t") pursuant to a trust agreement (the "Trust Agreement") between the Trustees and the Settlor. The Settlor 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 Settlor has the a
Settlor") created an irrevocable trust (the "Trust") pursuant to a trust agreement (the "Trust Agreement") between the Trustees and the Settlor. The Settlor 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
t") pursuant to a trust agreement (the "Trust Agreement") between the Trustees and the Settlor. The Settlor 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 Settlor has the a
ution Power"). The provision of the Trust Agreement eating thejSubstitution Power reads as follows: Cala _.e "Reacquisition of Trust Assets. The Settlor at any time or from time to time may acquire or reacquire any portion of the Trust Fund of any Trust by substituting therefor other property of an
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
ution Power"). The provision of the Trust Agreement eating thejSubstitution Power reads as follows: Cala _.e "Reacquisition of Trust Assets. The Settlor at any time or from time to time may acquire or reacquire any portion of the Trust Fund of any Trust by substituting therefor other property of an
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
Settlor") created an irrevocable trust (the "Trust") pursuant to a trust agreement (the "Trust Agreement") between the Trustees and the Settlor. The Settlor 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
t") pursuant to a trust agreement (the "Trust Agreement") between the Trustees and the Settlor. The Settlor 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 Settlor has the a
Settlor") created an irrevocable trust (the "Trust") pursuant to a trust agreement (the "Trust Agreement") between the Trustees and the Settlor. The Settlor 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
t") pursuant to a trust agreement (the "Trust Agreement") between the Trustees and the Settlor. The Settlor 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 Settlor has the a
the tru=t. Facts Petitioner (=he "Settlor") created an irrevocable trust (the "Trust"=) pursuant to a trust agreement between the Trustees and the Settlor. The =ettlor is deemed to own the Trust property for Federal and New York State income =ax purposes, as provided in §§ 671-679 of the Internal Reven
vocable trust (the "Trust"=) pursuant to a trust agreement between the Trustees and the Settlor. The =ettlor is deemed to own the Trust property for Federal and New York State income =ax purposes, as provided in §§ 671-679 of the Internal Revenue Code (I=C). Under the terms of the Trust Agreement, the Settlor has the admi
Entities connected to both Settlor and Federal and New York State

Samantha Power
PERSONthe Trust Fund of any Trust
ORGANIZATION
New York State
LOCATIONthe "Substituted Property
ORGANIZATIONN.Y.2d 458
ORGANIZATIONMartin Weinberg
PERSONRichman
PERSONDepartment of Taxation and Finance
ORGANIZATIONBrookhaven
LOCATIONSubstitution Power
ORGANIZATIONReacquisition of Trust Assets
ORGANIZATIONLeon Black
PERSONthe Trust Property
ORGANIZATIONthe Settlor's Substitution Power
ORGANIZATIONToscana
LOCATION
McGraw-Hill
ORGANIZATION
Exchange
ORGANIZATIONToscano
ORGANIZATIONMcGraw-Hill, Inc.
ORGANIZATION
New York City
LOCATION