Estate of Anthony J. Tamulis, Deceased, Wanda Rodgerson, Executor and Trustee - Page 23

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          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.                               






















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