Estate of Henry A. Lassiter, deceased, Paula Ann Masters Lassiter, administrator, C.T.A. - Page 53

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          proscribed by section 2056(b)(7)(B)(ii)(II).  Mrs. Lassiter’s                 
          interest therein thus constitutes a qualifying income interest                
          for life, and the estate is entitled to a deduction pursuant to               
          section 2056(b)(7).                                                           
               We conclude with a few brief comments on several of the                  
          additional arguments raised by the parties.  First, both                      
          respondent and the estate advocate positions regarding the                    
          validity of the disclaimer executed by Mrs. Lassiter in her                   
          capacity as trustee.  Because impermissible interests in the Item             
          V trust were effectively disclaimed by other renunciations, and               
          because Georgia law eliminates potentially suspect accumulation               
          or administrative powers in these circumstances, the trustee                  
          disclaimer is unnecessary for qualification.  To address its                  
          validity would be moot.  Due to possible broader implications,                
          however, we do say a few words about respondent’s general                     
          statement that, in interpreting the 1970 will, we must disregard              
          all of Mrs. Lassiter’s actions as trustee, apparently on the                  
          grounds that her appointment fails to comply with the terms of                
          Item X of the will.  Respondent seems to maintain that Item X                 
          limits the permissible trustee to a corporate entity.  We                     
               While the will may limit beneficiaries to appointment of a               
          corporate trustee when they choose to exercise their right to                 
          remove and replace an acting trustee, the document specifies no               

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