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contingent annuity |
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According to Example 5, if any amount of the annuity could be payable to a grantor's estate, the value of that contingent annuity interest had to reduce the amount of the grantor's retained trust value. Further, the court distinguished this case from Walton because the contingent annuity was payable to the grantor's estate when the grantor died. The power to revoke retained by the grantor should prevent the spousal contingent annuity from being a completed gift for gift tax purposes. |
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