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ATTACHMENT TO PETITION FOR ADVISORY OPINION State of New York — Department of Taxation and Finance - Form AD-1.8 4. The petitioner submits the following statement of facts as the basis for the requested advisory opinion: Facts as the basis for
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
ATTACHMENT TO PETITION FOR ADVISORY OPINION State of New York — Department of Taxation and Finance - Form AD-1.8 4. The petitioner submits the following statement of facts as the basis for the requested advisory opinion: Facts as the basis for
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
ATTACHMENT TO PETITION FOR ADVISORY OPINION State of New York — Department of Taxation and Finance - Form AD-1.8 4. The petitioner submits the following statement of facts as the basis for the requested advisory opinion: Facts as the basis for
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
ATTACHMENT TO PETITION FOR ADVISORY OPINION State of New York — Department of Taxation and Finance - Form AD-1.8 4. The petitioner submits the following statement of facts as the basis for the requested advisory opinion: Facts as the basis for
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 Department of Taxation and Finance and the Trust Property

New York State
LOCATION
Samantha Power
PERSONN.Y.2d 458
ORGANIZATIONRichman
PERSONSettlor
ORGANIZATIONBrookhaven
LOCATIONMartin Weinberg
PERSONReacquisition of Trust Assets
ORGANIZATIONthe Trust Fund of any Trust
ORGANIZATIONthe "Substituted Property
ORGANIZATIONFederal and New York State
ORGANIZATIONSubstitution Power
ORGANIZATIONToscana
LOCATION
McGraw-Hill
ORGANIZATIONthe Settlor's Substitution Power
ORGANIZATION