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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
to substitute trust property for property of equivalent value at any time (the "Substitution Power"). The provision of the Trust Agreement creating the Settlor's 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 Fu
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
to substitute trust property for property of equivalent value at any time (the "Substitution Power"). The provision of the Trust Agreement creating the Settlor's 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 Fu
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
to substitute trust property for property of equivalent value at any time (the "Substitution Power"). The provision of the Trust Agreement creating the Settlor's 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 Fu
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
to substitute trust property for property of equivalent value at any time (the "Substitution Power"). The provision of the Trust Agreement creating the Settlor's 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 Fu
Entities connected to both Settlor and the Settlor's Substitution Power

Samantha Power
PERSONFederal and New York State
ORGANIZATIONthe Trust Fund of any Trust
ORGANIZATIONthe "Substituted Property
ORGANIZATION
New York State
LOCATIONMartin Weinberg
PERSONRichman
PERSONDepartment of Taxation and Finance
ORGANIZATIONBrookhaven
LOCATIONSubstitution Power
ORGANIZATIONReacquisition of Trust Assets
ORGANIZATIONN.Y.2d 458
ORGANIZATIONthe Trust Property
ORGANIZATIONToscana
LOCATION
McGraw-Hill
ORGANIZATION