EFTA00001912.pdf

"Petitioner (the - Senior) created an irrevocable trust (the - Trust") pursuant to a trust agreement"

"the Senior is deemed to own the Trust property for Federal and Ncw York State income tax purposes"

"the Senior paid New York sales tax with respect to the Substituted Property"

"The petitioner submits the following statement of facts as the basis for the requested advisory opinion"

"the Settlor has the right to acquire or reacquire trust property at any time (the "Substitution Power")"