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APPENDIX
SEC. 671. TRUST INCOME, DEDUCTIONS, AND CREDITS
ATTRIBUTABLE TO GRANTORS AND OTHERS AS
SUBSTANTIAL OWNERS.
Where it is specified in this subpart that the
grantor or another person shall be treated as the owner
of any portion of a trust, there shall then be included
in computing the taxable income and credits of the
grantor or the other person those items of income,
deductions, and credits against tax of the trust which
are attributable to that portion of the trust to the
extent that such items would be taken into account
under this chapter in computing taxable income or
credits against the tax of an individual. Any
remaining portion of the trust shall be subject to
subparts A through D. No items of a trust shall be
included in computing the taxable income and credits of
the grantor or of any other person solely on the
grounds of his dominion and control over the trust
under section 61 (relating to definition of gross
income) or any other provision of this title, except as
specified in this subpart.
SEC. 672. DEFINITIONS AND RULES.
(a) Adverse Party.--For purposes of this subpart,
the term “adverse party” means any person having a
substantial beneficial interest in the trust which
would be adversely affected by the exercise or
nonexercise of the power which he possesses respecting
the trust. A person having a general power of
appointment over the trust property shall be deemed to
have a beneficial interest in the trust.
(b) Nonadverse Party.--For purposes of this
subpart, the term “nonadverse party” means any person
who is not an adverse party.
* * * * * * *
SEC. 677. INCOME FOR BENEFIT OF GRANTOR.
(a) General Rule.--The grantor shall be treated as
the owner of any portion of a trust, whether or not he
is treated as such owner under section 674, whose
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