 | 1960 - 880 lapas
...(ill) A power to reacquire the trust corpus by substituting other property of an equivalent value. If a power is exercisable by a person as trustee,...exercisable primarily in the interests of the beneficiaries. If a power is not exercisable by a person as trustee, the determination of whether the power is exercisable... | |
 | 1997 - 732 lapas
...or (Hi) A power to reacquire the trust corpus by substituting other property of an equivalent value. If a power is exercisable by a person as trustee,...exercisable primarily in the interests of the beneficiaries. If a power is not exercisable by a person as trustee, the determination of whether the power is exercisable... | |
 | 1998 - 732 lapas
...value. If a power is exerclsable by a person a« trustee, it is presumed that the power is exerclsable In a fiduciary capacity primarily in the interests...exercisable primarily in the interests of the beneficiaries. If a power is not exerclsable by a person as trustee, the determination of whether the power is exerclsable... | |
 | 1949 - 776 lapas
...capacity primarily in the interests of the beneficiaries. Such presumption may be rebutted only by a clear and convincing proof that the power is not exercisable primarily in the interests of the beneficiaries. If a power is not exercisable by a person as trustee, the determination of whether such power is exercisable... | |
 | 1961 - 566 lapas
...(iii) A power to reacquire the trust corpus by substituting other property of an equivalent value. If a power is exercisable by a person as trustee,...exercisable primarily in the interests of the beneficiaries. If a power is not exercisable by a person as trustee, the determination of whether the power is exercisable... | |
 | United States. Congress. House. Committee on Ways and Means - 1965 - 926 lapas
...506, 509 (2d Cir. 1945); Cashman v. Comm'r, 153 F. 2d 510, 514 (2d Cir. 1946); Harvey C. Fniehaitj, 12 TC 681, 690 (1949). In the Cushman case, the court...every charitable trustee would be false to his trust where control of a business is involved, and that a gift in such a case is, therefore, incomplete.... | |
 | United States. Tax Court - 1975 - 1272 lapas
...trustees which included the petitioner-grantor. Accordingly under section 1.675-l(b)(4), Income Tax Regs: If a power is exercisable by a person as trustee,...exercisable primarily in the interests of the beneficiaries. * * * Respondent argues that this presumption has been rebutted by the fact that the CR trusts made... | |
 | United States. Tax Court - 1975 - 1272 lapas
...trustees which included the petitioner-grantor. Accordingly under section 1.675-l(b)(4), Income Tax Regs: If a power is exercisable by a person as trustee,...exercisable primarily in the interests of the beneficiaries. * * * Respondent argues that this presumption has been rebutted by the fact that the CR trusts made... | |
 | 1975 - 550 lapas
...equivalent value. If a power is exercisable by a person as trustee, it is presumed that the power iB exercisable in a fiduciary capacity primarily in the...exercisable primarily in the interests of the beneficiaries. If a power is not exercisable by a person as trustee, the determination of whether the power is exercisable... | |
 | 1966 - 404 lapas
...(iii) A power to reacquire the trust corpus by substituting other property of an equivalent value. If a power is exercisable by a person as trustee,...exercisable primarily in the interests of the beneficiaries. If a power is not exercisable by a person as trustee, the determination of whether the power is exercisable... | |
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This presumption may be rebutted only by clear and convincing proof that the power is not exercisable primarily in the interests of the beneficiaries. 
