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2 Cards in this Set
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Estate of Nicol
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Section 2036
Mom leases land to daughter, transfers land 11 days later, continues to collect rent, dies before end of lease. Transfer is INCLUDIBLE in Gross Estate because Mom retained an interest (collecting rent) in the property for a period which did not in fact end before her death. |
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Estate of Grace
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"Reciprocal Trust"
H gives W lots of property. H sets up a trust for W. H has a trust set up for him from W's property and has her execute it. Substance over form. Two-prong test: 1. The trusts must be interrelated. 2. The arrangement, to the extent of mutual value, must leave the settlors "in approximately the same economic position" as they would have been in had each created his or her own trust. |
