Estate of Charles N. Aronson, Deceased, Barney P. Aronson, Executor - Page 35

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          for QTIP interests.  Estate of Nicholson v. Commissioner, supra             
          at 672.  A QTIP interest is one in which a decedent passes to the           
          surviving spouse a “qualifying income interest for life” and for            
          which an election has been made.  Sec. 2056(b)(7)(B)(i);6 Estate            
          of Nicholson v. Commissioner, supra.  Generally, when the                   
          surviving spouse has a “qualifying income interest for life”, she           


               6  Sec. 2056(b)(7)(B), in pertinent part, provides:                    
                    (7) Election with respect to life estate for surviving            
               spouse.--                                                              
                              *   *   *   *   *   *   *                               
                    (B) * * * For purposes of this paragraph--                        
                         (i) In general.--The term “qualified                         
                    terminable interest property” means                               
                    property–                                                         
                              (I) which passes from the decedent,                     
                              (II) in which the surviving spouse                      
                         has a qualifying income interest for                         
                         life, and                                                    
                              (III) to which an election under                        
                         this paragraph applies.                                      
                         (ii) Qualifying income interest for                          
                    life.--The surviving spouse has a qualifying                      
                    income interest for life if--                                     
                              (I) the surviving spouse is                             
                         entitled to all the income from the                          
                         property, payable annually or at more                        
                         frequent intervals, * * * and                                
                              (II) no person has a power to                           
                         appoint any part of the property to any                      
                         person other than the surviving spouse.                      




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