(taxpayer proposes to create charitable lead trust with required distributions from lead interest made to family private foundation or which taxpayer is founder/manager; IRS noted that tax benefits of trust during life and exclusion of trust property from grantor's gross estate at death can be achieved if donor acts appropriately with trust and foundation to ensure that gift is complete; IRS noted that grantor must separate himself from trust management (including trust funds received from foundation; IRS specified that donor cannot serve as trustee; while donor can be director of foundation, donor cannot vote on issues involving disbursements or decisions to distribute trust funds; under facts of ruling, quorum of foundation's Board, except the donor, established committee with sole authority to receive, invest and make all investment and administrative decisions, and distribution decisions on foundation's behalf; funds foundation receives to be segregated into separate account and committee will administer and distribute separate account, and donor will not have power over account).
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