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st") pursuant to a trust agreement (the "Trust Agreement") between the Trustees and the Settlor. The Senior 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 Senior has the ri
rookhaven, 80 Misc. 2d 563, N.Y.S.2d 731 (1975); Weiner v. McGraw-Hill, Inc. 57 N.Y.2d 458, 457 N.Y.S.2d 193, 443 N.E.2d 441 (2d Dep't 1982); In re Toscano, 799 F. Supp. 2d 230 (2011). Under the terms of the Trust Agreement, the Settlor alone, in a non-fiduciary capacity, decides whether to exercise th
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
rookhaven, 80 Misc. 2d 563, N.Y.S.2d 731 (1975); Weiner v. McGraw-Hill, Inc. 57 N.Y.2d 458, 457 N.Y.S.2d 193, 443 N.E.2d 441 (2d Dep't 1982); In re Toscano, 799 F. Supp. 2d 230 (2011). Under the terms of the Trust Agreement, the Settlor alone, in anon-fiduciary capacity, decides whether to exercise the
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
rookhaven, 80 Misc. 2d 563, N.Y.S.2d 731 (1975); Weiner v. McGraw-Hill, Inc. 57 N.Y.2d 458, 457 N.Y.S.2d 193, 443 N.E.2d 441 (2d Dep't 1982); In re Toscano, 799 F. Supp. 2d 230 (2011). Under the terms of the Trust Agreement, the Settlor alone, in anon-fiduciary capacity, decides whether to exercise the
Entities connected to both Federal and New York State and Toscano

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
ORGANIZATIONSubstitution Power
ORGANIZATIONMcGraw-Hill, Inc.
ORGANIZATION
Exchange
ORGANIZATIONthe Substitution Power(what Trust Property
ORGANIZATIONSqL.121,.titsjaular
ORGANIZATIONrespectlethe Substituted Property
ORGANIZATIONExchmgell
ORGANIZATIONExchan
LOCATIONthe "Trust property'
ORGANIZATION