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administration allocated annuity amount annuity trust Article attorney beneficiary benefit child Code credit shelter bequest death tax deemed determine direct skip discretion disposition drafting elective share estate or trust Executor and/or fair market value February 29 Federal Estate Tax Federal Gift Tax fiduciary fraction fund Generation-Skipping Transfer Tax give and bequeath grandchild gross estate GST exemption GST Tax Inclusion Ratio income tax Internal Revenue Code investment issue per stirpes lead trust legatee marital deduction Misc 2d N.Y. EPTL NYLJ October 22 Ordover paid payable payment pecuniary power of appointment prior Q-TIP QDOT QTIP trust qualify real property remainderman residuary estate rules SCPA skip person specific spouse's estate statute surviving spouse TAMRA 88 tangible personal property tate tax apportionment tax clause tax purposes taxable distribution taxable termination terminable interest testamentary testator's tion transferor trust assets Trustee shall pay unified credit unitrust amount York