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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
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
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
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
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
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
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
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 Federal and New York State and the Trust Property

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
LOCATIONSubstitution Power
ORGANIZATIONReacquisition of Trust Assets
ORGANIZATIONN.Y.2d 458
ORGANIZATIONthe Settlor's Substitution Power
ORGANIZATIONToscana
LOCATION
McGraw-Hill
ORGANIZATION