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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
the Settlor alone, in a non-fiduciary capacity, decides whether to exercise the Substitution Power and what property he will substitute in place of the Trust Property. The Trustees have no power either to consent or agree. Consequently, there is no negotiation or bargaining between the Settlor and the Trustees, 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
the Settlor alone, in a non-fiduciary capacity, decides whether to exercise the Substitution Power and what property he will substitute in place of the Trust Property. The Trustees have no power either to consent or agree. Consequently, there is no negotiation or bargaining between the Settlor and the Trustees, 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
the Settlor alone, in a non-fiduciary capacity, decides whether to exercise the Substitution Power and what property he will substitute in place of the Trust Property. The Trustees have no power either to consent or agree. Consequently, there is no negotiation or bargaining between the Settlor and the Trustees, 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
the Settlor alone, in a non-fiduciary capacity, decides whether to exercise the Substitution Power and what property he will substitute in place of the Trust Property. The Trustees have no power either to consent or agree. Consequently, there is no negotiation or bargaining between the Settlor and the Trustees, a
Entities connected to both Settlor and the Trust Property

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 Settlor's Substitution Power
ORGANIZATIONToscana
LOCATION
McGraw-Hill
ORGANIZATION