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ACTEC Notes administration allocation amount apply appraisal asset protection attorney benefit cash charitable ciary claim client Code Committee community property considered corporation counsel creditors death decedent decedent's designated beneficiary Determine discount distribution election entitled estate planning estate tax exempt fees Fellows fiduciary filed foreign trust funds gift tax grantor trust held income tax intent interest investment issue lawyers liability litigation marital deduction Meeting ment partnership payment percent plain meaning rule power of appointment prior private letter rulings probate QTIP trust qualified plan reformation remainderman result Review revocable trust separate share rule Service settlor split dollar spouse's statute supra note surviving spouse tax purposes taxable taxpayer testator's tion transfer tax Treas treated trust and estate trust instrument Trust Law Trusts 3d U.S. person valuation