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of the GRAT, and are therefore contingent, and because the
retained interests may extend beyond the shorter of a term of
years or the period ending upon the death of the grantor, we hold
that the retained interests in the trusts at issue here are to be
valued as single-life annuities. See secs. 25.2702-3(d)(3) and
25.2702-2(a)(5), Gift Tax Regs. We sustain respondent’s
determinations to that effect.
We have considered other arguments made by the parties, and
to the extent not addressed, we find them to be unconvincing,
irrelevant, or moot.
To reflect the foregoing,
An Order will be issued
denying petitioners’ Motion
for Partial Summary Judgment
and granting respondent’s
Motion for Partial Summary
Judgment.
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