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2702 5 c contains the requirements that must be met by a trust in order to qualify as a QPRT. This revenue procedure provides a sample declaration of trust as well as additional guidance in the form of annotations and alternative provisions. SECTION 3. SCOPE AND OBJECTIVE Section 4 of this revenue procedure provides a sample declaration of trust for a QPRT with one transferor for a term equal to the lesser of the life of the term holder or a term....
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