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Q: D creates a trust with income payable for D's lie either to A or to B, as D directs, remainder to C or C's

Q: D creates a trust with income payable for D's lie either to A or to B, as D directs, remainder to C or C's estate. D retains a power to revoke. Assume A, B and C are unrelated to D. a. Does D make a completed gift at the time of creation of the trust? b. At D's direction, the first year's income is paid equally to A and B. Are there any gifts? c. In addition, D relinquishes D's power to revoke at the end of year 1, but not D's right to direct income payments. Is there a further gift? d. In addition to the facts of part c. above, at the end of the year 2 D directs that the year's income be paid to A and effectively further directs that all remaining income during D's life be paid to A or A's estate. Are there any gifts? e. Would D have made a completed gift of the entire trust property if D had simply created a trust with income to A for ten years, remainder to A or A's estate, and D retained a power to accumulate income?

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