- 23 - in August 2002 or the 2003 amendment in August 2003, was commenced before respondent contacted the estate for an audit-- precisely the circumstances where Congress intended that reformation could not be initiated. If the estate's position regarding substantial compliance were accepted, then the reformation requirements of section 2055(e)(3) could be circumvented by means of a simple disclosure on the return that a CRUT (or CRAT) was intended, without regard to the actual terms of the trust's governing instrument. We have considered the estate's remaining arguments and conclude they are without merit or relevance. For the foregoing reasons, Decision will be entered for respondent.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23
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