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01-1471 Cook v. Commissioner of the Internal Revenue Service

"When we examine the terms of the Cooks' respective GRATs, we also agree that the spousal interests contained in each are not 'qualified interests' under section 2702. First and foremost, the interests are contingent. Under both the 1993 and 1995 GRATs, a spouse is entitled to income only if: (1) the spouse survived the grantor ...

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