- 26 -
Based on the foregoing, we find that the amended trust
property in the instant case does not qualify for either the
section 2056(b)(5) or the section 2056(b)(7) exception to the
section 2056(b)(1) terminable interest rule.
We have considered all of the contentions and arguments of
the parties that are not discussed herein, and we find them to be
without merit, irrelevant, or moot.
To reflect the foregoing,
Decision will be entered
for respondent.
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