- Ag Docket
(reformation of trust by court would not disqualify trust's tax status under I.R.C. Sec. 664 if trust distributes all amounts to beneficiary from prior years within 120 days of receipt of private letter ruling; reformation was not self-dealing under I.R.C. Sec. 4941; trust was created with intent to provide lifetime annual income to beneficiary by virtue of a CRUT, but scrivenor used wrong form and created net income with makeup charitable remainder unitrust (NIMCRUT); petition filed to reform trust to a CRUT).
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