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uivalent value to the Substituted Property (the "Exchange"). Upon the initial purchase of 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 Substitu
ire trust property at any time (the "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 pr
n would not constitute either (i) a retail sale of tangible personal property or (ii) a purchase of tangible personal property at retail subject to New York State and City sales and/or compensating use tax because there is no consideration in connection with the Substitution. The partial definitions of consid
ent 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 Fund of any Trust by substituting therefor other pr
n would not constitute either (i) a retail sale of tangible personal property or (ii) a purchase of tangible personal property at retail subject to New York State and City sales and/or compensating use tax because there is no consideration in connection with the Substitution. The partial definitions of consid
ent 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 Fund of any Trust by substituting therefor other pr
e would not constitute either (i) a retail sale of tangible personal property or (ii) a purchase of tangible personal property at retail subject to New York State and City sales and/or compensating use tax because there is no consideration in connection with the Exchange. The partial definitions of considerat
st props at any time (the "Substitution 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 pr
e would not constitute either (i) a retail sale of tangible personal property or (ii) a purchase of tangible personal property at retail subject to New York State and City sales and/or compensating use tax because there is no consideration in connection with the Exchange. The partial definitions of considerat
st props at any time (the "Substitution 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 pr
n would not constitute either (i) a retail sale of tangible personal property or (ii) a purchase of tangible personal property at retail subject to New York State and City sales and/or compensating use tax because there is no consideration in connection with the Substitution. The partial definitions of consid
ent 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 Fund of any Trust by substituting therefor other pr
n would not constitute either (i) a retail sale of tangible personal property or (ii) a purchase of tangible personal property at retail subject to New York State and City sales and/or compensating use tax because there is no consideration in connection with the Substitution. The partial definitions of consid
ent 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 Fund of any Trust by substituting therefor other pr
Entities connected to both New York State and Reacquisition of Trust Assets

Samantha Power
PERSONMartin Weinberg
PERSONDepartment of Taxation and Finance
ORGANIZATIONFederal and New York State
ORGANIZATIONSettlor
ORGANIZATIONthe Trust Fund of any Trust
ORGANIZATIONthe "Substituted Property
ORGANIZATIONBrookhaven
LOCATIONN.Y.2d 458
ORGANIZATIONRichman
PERSONSubstitution Power
ORGANIZATION
Exchange
ORGANIZATIONToscana
LOCATIONthe Settlor's Substitution Power
ORGANIZATION
McGraw-Hill
ORGANIZATIONthe Trust Property
ORGANIZATIONToscano
ORGANIZATIONMcGraw-Hill, Inc.
ORGANIZATIONthe "Trust property'
ORGANIZATIONExchmgell
ORGANIZATION