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aﬁer agreement amount annual apply assets attorney beneﬁciary designation charitable remainder Commissioner community property credit shelter trust D's death D's estate death beneﬁts decedent decedent's deferral deﬁciency deﬁned beneﬁt plan deﬁned contribution plans designated beneﬁciary disclaimer employee equitable tolling ERISA estate tax estate's excess accumulations tax excess retirement accumulations executor ﬁled ﬁrst ﬁve ﬁve-year averaging fund generation-skipping transfer tax giﬁ gift tax grandfathered grantor gross estate includible income tax individual retirement accounts irrevocable lump sum distribution marital deduction million minimum distribution rules paid participant participant's death payable payout pension plans percent power of appointment QPSA QTIP election QTIP trust qualiﬁed plan beneﬁts receive reﬂect required beginning date residuary estate retirement beneﬁts revocable trust Section shares speciﬁc spousal consent spousal rollover spouse's statute survivor annuity T.C. Memo Tax Court tax on excess tax-free taxable transfer unitrust valuation withdrawal right