The principal of a Chicago high school has been suspended over his handling of a student who wore a German soldier's uniform and gave a Nazi salute onstage during a Halloween costume contest. (7) disbursements related to environmental matters, includingreclamation, assessing environmental conditions, remedying and removing environmental contamination, monitoring remedial activities and therelease of substances, preventing future releases of substances collecting amounts from persons liable or potentially liable for the costs of those activities, penalties imposed under environmental laws orregulations and other payments made to comply with those laws orregulations, statutory or common law claims by third parties, and defending claims based on environmental matters. (d) An income interest ends on the day before an income beneficiary, dies or another terminating event occurs, or on the last day of a period, during which there is no beneficiary to whom a trustee may distribute, 11-A-3.2 Apportionment of receipts and disbursements when decedent, (a) A trustee shall allocate an income receipt or disbursement other, than one to which paragraph 11-A-2.1 (1) applies to principal if its due, date occurs before a decedent dies in the case of an estate or before an, income interest begins in the case of a trust or successive income, (b) A trustee shall allocate an income receipt or disbursement to, income if its due date occurs on or after the date on which a decedent, dies or an income interest begins and it is a periodic due date. The Refectory Kitchen & Terrace restaurant serves a wide variety of British cuisine. The majority of the rooms are in the main house, and the grandest of them look out across the gardens to York Minster in the distance. (b) An amount received on account of an interest in water that is renewable must be allocated to income. Additionally, a video of the costume parade has since appeared on social media, he said in the email.I certainly understand and regret the discomfort and harm felt by some members of our school community. A fiduciary may make adjustments between principal and income tooffset the shifting of economic interests or tax benefits between incomebeneficiaries and remainder beneficiaries which arise from: (1) elections and decisions that the fiduciary makes from time to timeregarding tax matters; (2) an income tax or any other tax that is imposed upon the fiduciary or a beneficiary as a result of a transaction involving or adistribution from the estate or trust; or. (b) A trustee who accounts separately for a business or other activity may determine the extent to which its net cash receipts must be retainedfor working capital, the acquisition or replacement of fixed assets, and other reasonably foreseeable needs of the business or activity, and the extent to which the remaining net cash receipts are accounted for as principal or income in the trusts general accounting records. Furthermore, CPS has removed the schools leader from their principal duties, effective immediately, pending the results of that investigation, Martinez added. They should have set him aside and had a conversation with him about why it was inappropriate, Rodas added. Is Rental Property Income Eligible for the Pass Through IncomeDeduction? If a trustee purchases an interest in a trust that isan investment entity, or a decedent or donor transfers an interest insuch a trust to a trustee, 11-A-4.1 or 11-A-4.15 applies to a receiptfrom the trust. Judicial Code means title 28 of the United States Code, 28 U.S.C. If apayment is one of a series of payments that will result in theliquidation of the trusts interest in the security over more than oneaccounting period, the trustee shall allocate ten percent of the paymentto income and the balance to principal. Certain units feature updated interior along with heated flooring. This cookie is set by GDPR Cookie Consent plugin. On Friday, the CTU called on Powers to step down. Maximum capacity of extra beds in a room is 1. Necessary cookies are absolutely essential for the website to function properly. We've received your submission. interest begins or ends when an income interest ends. Well be unveiling this extra special project very soon. (a) Except as otherwise provided in paragraph (b), a trustee shall, allocate to principal the proceeds of a life insurance policy or other. Sticking to his weekly ritual, New York Jets owner Woody Johnson returned to Twitter on Friday morning to announce what uniform combination the Jets will be wearing in their upcoming game. Please wait, we're checking available rooms for you. assets are segregated from other trust assets. Your spouse, if not legally separated from you, or your domestic partner. ALLOCATION OF RECEIPTS DURING ADMINISTRATION OF TRUST. (11) Remainder beneficiary means a person entitled to receive principal when an income interest ends. I. at 249. The increment in value of a bond or other obligation forthe payment of money bearing no stated interest but payable or redeemable at maturity or at a future time at an amount in excess of theamount in consideration of which it was issued is income. In the latter case, the, undistributed income from the portion of the trust that may be revoked, (c) When a trustees obligation to pay a fixed annuity or a fixed, fraction of the value of the trusts assets ends, the trustee shall, prorate the final payment if and to the extent required by applicable, law to accomplish a purpose of the trust or its settlor relating to. Distributions to shareholdersor other owners from an entity to which 11-A-4.1 applies are deemed tobe due on the date fixed by the entity for determining who is entitled to receive the distribution or, if no date is fixed, on the declarationdate for the distribution. 11-A-2.2 Distribution to residuary and remainder beneficiaries. Blending the grandeur of late-Victorian architecture with the comforts of modern travel, The Principal York offers its guests the warmest welcome this side of the Pennines. necessary to obtain the marital deduction. (a) A tax required to be paid by a trustee based on receipts allocatedto income must be paid from income. This week saw the launch of their most ambitious project to date: Principal London. (3) The beneficiarys fractional interest in the undistributedprincipal assets must be calculated on the basis of the aggregate valueof those assets as of the distribution date without reducing the valueby any unpaid principal obligation. For the former, we have created polo shirts with branded embroidery, worn with bespoke half aprons. (b) Except as otherwise provided in this section, a trustee shall. L. REVISION COMM'N]. . This article takes effect on January first, two thousand two. (b) In determining a beneficiarys share of net income, the followingrules apply: (1) The beneficiary is entitled to receive a portion of the net incomeequal to the beneficiarys fractional interest in the undistributed principal assets immediately before the distribution date, includingassets that later may be sold to meet principal obligations. York,32 the New York Court of Appeals considered a challenge to four investments held in trust.33 During the four years the trust was managed, . (c) This article applies whether or not a decedent or transferor washarvesting timber from the property before it became subject to thetrust. The Chicago Teachers Union also has issued a statement condemning the incident, saying the principal has been plagued for years with charges that include persistent racial intolerance.Everyone at Jones suffers as behavior such as this goes unchecked and undisciplined, and for Mayor Lori Lightfoot and Chicago Public Schools to keep the current administration in place shows their lack of regard for the families, faculty and staff they should be protected, said union rep Chris Geovanis, according to Block Club Chicago. Each hotel - Principal Manchester, Principal Edinburgh and Principal York - are set in heritage buildings and have their own unique character; the challenge was to . (3) If an amount received as a royalty, shut-in-well payment, take-or-pay payment, bonus, or delay rental is more than nominal, ninety. We looked at both traditional and contemporary cuts, as well as signature accessories associated with tailored styles. An, income receipt or disbursement must be treated as accruing from day to, day if its due date is not periodic or it has no due date. (b) To the extent that a trustee does not account under 11-A-4.3 for, transactions in derivatives, the trustee shall allocate to principal, receipts from and disbursements made in connection with those. Principal York Hotel is within only 10 minutes' walk from York city centre. At Principal York you can pay with American Express, Mastercard and Visa. whether or not appointed or confirmed by a court. available for the personal use or enjoyment of a beneficiary; (3) under this section if the trustee is accounting under 11-A-4.3 for. What famous landmarks can we find near Principal York Hotel? 2010 New York Code EPT - Estates, Powers & Trusts Article 11-A - UNIFORM PRINCIPAL AND INCOME ACT Part 1 - (11-A-1.1 - 11-A-1.3) DEFINITIONS AND FIDUCIARY DUTIES Part 2 - (11-A-2.1 - 11-A-2.2) DECEDENT'S ESTATE OR TERMINATING INCOME INTEREST Part 3 - (11-A-3.1 - 11-A-3.3) APPORTIONMENT AT BEGINNING AND END OF INCOME INTEREST The cookie is used to store the user consent for the cookies in the category "Analytics". (12) Terms of a trust means the manifestation of the intent of asettlor or decedent with respect to the trust, expressed in a manner that admits of its proof in a judicial proceeding, whether by written orspoken words or by conduct. All rights reserved. (4) If an amount is received from a working interest or any otherinterest not provided for in subparagraph (1), (2), or (3), ninety percent of the net amount received must be allocated to principal andthe balance to income. (4) shall add a receipt or charge a disbursement to principal to theextent that the terms of the trust or the will and this article do not provide a rule for allocating the receipt or disbursement to or betweenprincipal and income. The UPIA directs the trustee to allocate first according to the trust. Thebalance must be allocated to principal. For the latter, maintenance staff wear a durable and wearable range of polo shirts, cargo pants and soft shell outerwear. (13) Trustee includes an original, additional, or successor trustee. the asset is required to deliver the asset if the option is exercised, an amount received for granting the option must be allocated to, principal. We have also developed uniform for the hotels housekeeping and maintenance staff. The, term does not include a payment subject to 11-A-4.9, resources subject, to 11-A-4.11, timber subject to 11-A-4.12, an activity subject to, 11-A-4.14, an asset subject to 11-A-4.15, or any asset for which the. receipts described in subparagraph (1) and clause (A). Change). 11-A-4.7 Insurance policies and similar contracts. (9) Person means an individual, corporation, business trust, estate, trust, partnership, limited liability company, association, joint, venture, government; governmental subdivision, agency, or, instrumentality; public corporation, or any other legal or commercial, (10) Principal means property held in trust for distribution to a. remainder beneficiary when the trust terminates. section, the trustee shall allocate them as follows: (1) If received as nominal delay rental or nominal annual rent on a. lease, a receipt must be allocated to income. Whenever unrealized increment is distributed as incomebut out of principal the principal shall be reimbursed from the income when realized. (a) An amount received as interest, whether determined at a fixed,variable, or floating rate, on an obligation to pay money to thetrustee, including an amount received as consideration for prepayingprincipal, must be allocated to income without any provision foramortization of premium. The term includes an executor, administrator, successor personal representative, and a person performing substantially the same function. If no part of a payment is required to be made or the payment, received is the entire amount to which the trustee is entitled, the, trustee shall allocate the entire payment to principal. (4) The distribution date for purposes of this section may be the dateas of which the fiduciary calculates the value of the assets if thatdate is reasonably near the date on which assets are actuallydistributed. (3) A fiduciary shall distribute to a beneficiary who receives a pecuniary amount outright the interest or any other amount provided bythe will, the terms of the trust, or applicable law from net incomedetermined under paragraph (2) or from principal to the extent that netincome is insufficient. (a) In allocating receipts and disbursements to or between principaland income, and with respect to any matter within the scope of parts 2and 3, a fiduciary: (1) shall administer a trust or estate in accordance with the terms ofthe trust or the will, even if there is a different provision in thisarticle; (2) may administer a trust or estate by the exercise of a discretionary power of administration given to the fiduciary by theterms of the trust or the will, even if the exercise of the powerproduces a result different from a result required or permitted by thisarticle; (3) shall administer a trust or estate in accordance with this articleif the terms of the trust or the will do not contain a different provision or do not give the fiduciary a discretionary power ofadministration; and. The nearest airport is Leeds Bradford and it is placed within 47 minutes' drive. In the latter case, the undistributed income from the portion of the trust that may be revoked must be added to principal. Yes, Principal York Hotel provides rooms with facilities for disabled and wheelchair access to cater to special guests' needs. (3) the ownership by an estate or trust of an interest in an entitywhose taxable income, whether or not distributed, is includable in thetaxable income of the estate, trust, or a beneficiary. principal. Naturally, we looked to each citys individual characters for inspiration, such as the rich history of music and science in Manchester (where we recently revealed a behind-the-scenes fitting) and the vast history of textile prints in Edinburgh. (b) To the extent that a payment is characterized as interest or a dividend or a payment made in lieu of interest or a dividend, a trustee shall allocate it to income. (2) Beneficiary includes, in the case of a decedents estate,a, distributee and testamentary beneficiary and, in the case of a trust, an. (c) If a fiduciary does not distribute all of the collected butundistributed net income to each person as of a distribution date, thefiduciary shall maintain appropriate records showing the interest ofeach beneficiary in that net income. The trustee may decide which action or combination of actions to, (b) In cases not governed by paragraph (a), proceeds from the sale or, other disposition of an asset are principal without regard to the amount. (1) to the extent not allocated to income under this article, assets received from a transferor during the transferors lifetime, adecedents estate, a trust with a terminating income interest, or a payer under a contract naming the trust or its trustee as beneficiary; (2) money or other property received from the sale, exchange, liquidation, or change in form of a principal asset, including realized profit, subject to this part; (3) amounts recovered from third parties to reimburse the trustbecause of disbursements described in subparagraph 11-A-5.2 (a)(7) orfor other reasons to the extent not based on the loss of income; (4) proceeds of property taken by eminent domain, but a separate award made for the loss of income with respect to an accounting period duringwhich a current income beneficiary had a mandatory income interest is income; (5) net income received in an accounting period during which there isno beneficiary to whom a trustee may or must distribute income; and. section. (b) In determining net receipts to be allocated pursuant to paragraph (a), a trustee shall deduct and transfer to principal a reasonableamount for depletion. Be sure to enjoy a meal at Refectory, the onsite restaurant. (4) to principal to the extent that advance payments, bonuses, andother payments are not allocated pursuant to subparagraph (1), (2), or (3). Charles DeBerry, principal of P.S. We held a costume contest in the afternoon during Ac Lab, which was fun and well-received, the Chicago Tribune reported. (a) To the extent that a trustee accounts for receipts from the sale of timber and related products pursuant to this section, the trustee shall allocate the net receipts: (1) to income to the extent that the amount of timber removed from theland does not exceed the rate of growth of the timber during theaccounting periods in which a beneficiary has a mandatory income interest; (2) to principal to the extent that the amount of timber removed from the land exceeds the rate of growth of the timber or the net receiptsare from the sale of standing timber; (3) to or between income and principal if the net receipts are from the lease of timberland or from a contract to cut timber from land ownedby a trust, by determining the amount of timber removed from the landunder the lease or contract and applying the rules in subparagraphs (1)and (2); or. (2) Principal is property, disposed of in trust, the income from which is payable to or to be accumulated for an income beneficiary and the title to which is ultimately to vest in the person entitled to the future estate. Lorenzo Chambers, the principal of P.S. shall allocate receipts from the interest as provided in this article. Working in three individual cities across three unique locations was a dream come true for the team. The principal of a Chicago high school has been suspended over his handling of a student who wore a German soldier's uniform and gave a Nazi salute onstage during a. income and remainder interests or that concern primarily principal, including a proceeding to construe the trust or to protect the trust or, (6) estate, inheritance, and other transfer taxes, including, (7) disbursements related to environmental matters, including, reclamation, assessing environmental conditions, remedying and removing, environmental contamination, monitoring remedial activities and the, release of substances, preventing future releases of substances, collecting amounts from persons liable or potentially liable for the, costs of those activities, penalties imposed under environmental laws or, regulations and other payments made to comply with those laws or, regulations, statutory or common law claims by third parties, and. (b) To the extent that a trustee does not account under 11-A-4.3 for transactions in derivatives, the trustee shall allocate to principalreceipts from and disbursements made in connection with thosetransactions. Recently bought out by IHG, the York Principal is now the only one with the "Principal" name. 11-A-4.2 Distribution from trust or estate. section applies to the income from the asset. In the meantime, across the country, the award-winning sister sites of the Principal Hotel Company also required brand new uniforms for hundreds of staff across multiple roles. Change), You are commenting using your Facebook account. Home History of the Hotel Rooms & Suites Standard Rooms Premium Rooms Suites Eat & Drink Meetings & Conferences Meetings & Event Spaces Meeting & Events Enquiry Weddings & Events Wedding Christmas and New Year Leisure & Pool (a) In this section, undistributed income means net income receivedbefore the date on which an income interest ends. beneficiaries and remainder beneficiaries which arise from: (1) elections and decisions that the fiduciary makes from time to time, (2) an income tax or any other tax that is imposed upon the fiduciary, or a beneficiary as a result of a transaction involving or a, distribution from the estate or trust; or, (3) the ownership by an estate or trust of an interest in an entity, whose taxable income, whether or not distributed, is includable in the. (b) A trustee shall allocate to income ten percent of the receipts. Home History of the Hotel Rooms & Suites Standard Rooms Premium Rooms Suites Eat & Drink Meetings & Conferences Meetings & Event Spaces An amount paid to acquire the option must be paid fromprincipal. (c) If no part of a payment is characterized as interest, a dividend, or an equivalent payment, and all or part of the payment is required to be made, a trustee shall allocate to income ten percent of the part that is required to be made during the accounting period and the balance to principal. |. contract in which the trust or its trustee is named as beneficiary, including a contract that insures the trust or its trustee against loss, for damage to, destruction of, or loss of title to a trust asset. (LogOut/ (2) Beneficiary includes, in the case of a decedents estate,adistributee and testamentary beneficiary and, in the case of a trust, anincome beneficiary and a remainder beneficiary. Our Suites have listed interior details with magnificent views of the Minster and hotel gardens. 11-A-5.3 Transfers from income to principal for depreciation. (4) Income means money or property that a fiduciary receives as current return from a principal asset. investment advisory or custodial services to the trustee; (2) if the court shall find that any judicial proceeding primarily, concerns income and that it is equitable to charge the expense of such, proceeding, or a part thereof, to income, the court may direct that all, or a specified part of the expense of such proceeding, including. Principal York Hotel is located in the very heart of York, right near The Bars. The term includes a payment made, in money or property from the payers general assets or from a separate, fund created by the payer, including a private or commercial annuity, an. We use cookies to ensure that we give you the best experience on our website. Contents 1 The 1853 Hotel 2 The 1878 Hotel 3 British Transport Hotels 4 Privatisation 5 References For purposes of, this paragraph, a payment is not required to be made to the extent. (f) A trustee may rely upon a statement made by an entity about thesource or character of a distribution if the statement is made at or near the time of distribution by the entitys board of directors or other person or group of persons authorized to exercise powers to pay money or transfer property comparable to those of a corporations boardof directors. of a terminating income interest, including debts, funeral expenses, disposition of remains, family allowances, and death taxes and related, penalties that are apportioned to the estate or terminating income. (5) A fiduciary may not reduce principal or income receipts from, property described in paragraph (1) because of a payment described in, 11-A-5.1 or 11-A-5.2 to the extent that the will, the terms of the, trust, or applicable law requires the fiduciary to make the payment from, assets other than the property or to the extent that the fiduciary, recovers or expects to recover the payment from a third party. the primary themes of the act include both increasing and focusing of these default rules.23 since the act now covers a broader array of categories of trust receipts and disbursements, it is more important than ever for the drafter of net-income unitrusts to place the desired accounting rules into the text of the document, at least to the extent distribution shall be considered to be a distribution of money; (2) money received in one distribution or a series of related, distributions in exchange for part or all of a trusts interest in the, (4) money received from an entity that is a regulated investment, company or a real estate investment trust if the money distributed is a. capital gain dividend for federal income tax purposes. It does not store any personal data. Id. YO24 1AA Main amenities in Principal York Hotel are represented by a sauna, a health club and an indoor swimming pool. for other reasons to the extent not based on the loss of income; (4) proceeds of property taken by eminent domain, but a separate award, made for the loss of income with respect to an accounting period during, which a current income beneficiary had a mandatory income interest is, (5) net income received in an accounting period during which there is, no beneficiary to whom a trustee may or must distribute income; and, To the extent that a trustee accounts for receipts from rental, property pursuant to this section, the trustee shall allocate to income, an amount received as rent of real or personal property, including an, amount received for cancellation or renewal of a lease. (a) A trustee shall make the following disbursements from principal: (1) the remaining two-thirds of the disbursements described in paragraph 11-A-5.1 (1); (2) all of the trustees compensation calculated on principal as a feefor acceptance, distribution, or termination, and disbursements made toprepare property for sale; (3) payments on the principal of a trust debt; (4) except as provided in paragraph 11-A-5.1 (2), all expenses foraccountings, judicial proceedings or other matters that involve both the income and remainder interests or that concern primarily principal,including a proceeding to construe the trust or to protect the trust orits property; (5) premiums paid on a policy of insurance not described in paragraph. Uniform Commercial Code Financing Statement is available online and by paper. (LogOut/ The student said the uniform-wearing boy has made racist comments in the past, the staffer told the outlet on condition of anonymity. APPORTIONMENT AT BEGINNING AND END OF INCOME INTEREST, 11-A-3.1 When right to income begins and ends. Combining style with wearability is always at the forefront of our designs, and this particular project called for equal amounts of both. (2) The beneficiarys fractional interest in the undistributed, principal assets must be calculated withoutregardtoproperty, specifically given to a beneficiary and property required to pay, (3) The beneficiarys fractional interest in the undistributed, principal assets must be calculated on the basis of the aggregate value, of those assets as of the distribution date without reducing the value, (4) The distribution date for purposes of this section may be the date, as of which the fiduciary calculates the value of the assets if that, date is reasonably near the date on which assets are actually, (c) If a fiduciary does not distribute all of the collected but, undistributed net income to each person as of a distribution date, the, fiduciary shall maintain appropriate records showing the interest of, (d) A fiduciary may apply the rules in this section, to the extent, that the fiduciary considers it appropriate, to net gain or loss, realized after the date of death or terminating event or earlier, distribution date from the disposition of a principal asset if this. The result is a collection of smart, classic tailored mix and match pieces. York Principal Hotel. financial statements immediately preceding the initial receipt. Guests can also enjoy views of the garden. An old Victorian station hotel, the architecture is impressive. (a) In this section, asset-backed security means an asset whosevalue is based upon the right it gives the owner to receivedistributions from the proceeds of financial assets that providecollateral for the security. An income interest begins on the date, specified in the terms of the trust or, if no date is specified, on the. This incident caused harm to many students and staff, and it is completely inconsistent with our values as a school district, he said. whether or not the trust owns the property when the option is granted, grants an option that permits another person to sell property to the, trust, or acquires an option to buy property for the trust or an option, to sell an asset owned by the trust, and the trustee or other owner of. (d) For purposes of this section, receipt allocated to principal or, income must be reduced by the amount distributed to a beneficiary from, principal or income for which the trust receives a deduction in, A fiduciary may make adjustments between principal and income to, offset the shifting of economic interests or tax benefits between income. They were protesting Mr. The behavior never changes, and [Powers] never does anything about it, the staff member told Block Club Chicago. By clicking above you agree to the Terms of Use (c) A tax required to be paid by a trustee on the trusts share of anentitys taxable income must be paid proportionately: (1) from income to the extent that receipts from the entity areallocated to income; and, (A) receipts from the entity are allocated to principal; and. 11-A-3.2 Apportionment of receipts and disbursements when decedent dies or income interest begins. The. Section 11-A-4.4 Principal receipts. (4) money received from an entity that is a regulated investment company or a real estate investment trust if the money distributed is a capital gain dividend for federal income tax purposes. (1) to the extent that the entity, at or near the time of a, distribution, indicates that it is a distribution in partial, (2) if the total amount of money and property received in a, distribution or series of related distributions is greater than twenty, percent of the entitys gross assets, as shown by the entitys year-end. income, gift, estate, or other tax requirements. (5) Income beneficiary means a person to whom net income of a trustis or may be payable. 11-A-5.6 Adjustments between principal and income because of taxes. Field Notes is the journal of uniform design studio Field Grey. (2) A fiduciary shall determine the remaining net income of a, decedents estate or a terminating income interest under the rules in. Senior Yamali Rodas said she plans to participate.Im kind of disappointed in the way that administration has responded, Rodas, who heads the schools Association of Latin American Students, told the Sun-Times. This power may be exercised by a cotrustee in the circumstances described in subparagraph 11-2.3 (b)(5) and may be released for the reasons and in the manner described in thatsection. If the trust acquires an interest in minerals, water, or other, natural resources after the effective date of this article, the trustee. Stay up on the very latest with Evening Update. tenant allowances, leasehold improvements, and brokers commissions; (4) periodic payments on an obligation secured by a principal asset to, the extent that the amount transferred from income to principal for, depreciation is less than the periodic payments; and, (c) If the asset whose ownership gives rise to the disbursements, becomes subject to a successive income interest after an income interest, ends, a trustee may continue to transfer amounts from income to, (a) A tax required to be paid by a trustee based on receipts allocated, (b) A tax required to be paid by a trustee based on receipts allocated, to principal must be paid from principal, even if the tax is called an, (c) A tax required to be paid by a trustee on the trusts share of an. All children under the age of 13 may stay at the price of GBP 30 per person per night in an extra bed. (b) A trustee shall allocate to income proceeds of a contract that insures the trustee against loss of occupancy or other use by an income beneficiary, loss of income, or, subject to 11-A-4.3, loss of profits from a business. The sprawling property is set in beautifully landscaped gardens, lined with perfectly manicured hedges and a huge wrought-iron gate at the entrance. All rights reserved. If any provision of this article or its application to any person orcircumstance is held invalid, the invalidity does not affect other provisions or applications of this article which can be given effectwithout the invalid provision or application, and to this end theprovisions of this article are severable. (d) If, to obtain an estate tax marital deduction for a trust, atrustee must allocate more of a payment to income than provided for bythis section, the trustee shall allocate to income the additional amount necessary to obtain the marital deduction.
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