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r has the fight to as t.b.e ca-PiliNquire trust property, at any time (the "Substitution Power"). The provision of the Trust Agreer e it ating the,Substitution Power reads as follows: "Reacquisition of Ti Assets. The Settlor at any time or from time to time may acquire or reacquire any portion of the Trust Fund
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
r and the Trustees, as there is no need to induce or motivate either party to enter into the Substitution. Once the Settlor decides to exercise his Substitution Power (considered a general power of administration under Section 675 of the Internal Revenue Code) the Trustees must comply with the terms of the Trust
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
r and the Trustees, as there is no need to induce or motivate either party to enter into the Substitution. Once the Settlor decides to exercise his Substitution Power (considered a general power of administration under Section 675 of the Internal Revenue Code) the Trustees must comply with the terms of the Trust
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
ttlor and the Trustees, as there is no need to induce or motivate either party to enter into the Exchange. Once the Settlor decides to exercise his Substitution Power (considered a general power of administration under Section 675 of the Internal Revenue Code) the Trustees must comply with the terms of the Trust
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
ttlor and the Trustees, as there is no need to induce or motivate either party to enter into the Exchange. Once the Settlor decides to exercise his Substitution Power (considered a general power of administration under Section 675 of the Internal Revenue Code) the Trustees must comply with the terms of the Trust
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
r and the Trustees, as there is no need to induce or motivate either party to enter into the Substitution. Once the Settlor decides to exercise his Substitution Power (considered a general power of administration under Section 675 of the Internal Revenue Code) the Trustees must comply with the terms of the Trust
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
r and the Trustees, as there is no need to induce or motivate either party to enter into the Substitution. Once the Settlor decides to exercise his Substitution Power (considered a general power of administration under Section 675 of the Internal Revenue Code) the Trustees must comply with the terms of the Trust
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
Entities connected to both Substitution Power and Federal and New York State

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