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Outright Development is a Boston Massachusetts web development and mobile app development company specializing in custom software for business.
Although it is easy to determine whether an outright gift is subject to GST tax, gifts to trusts are more problematic and present a potential danger, especially when relying only on the automatic allocation rules.
Established in 1999 with a series of 13 nine-minute stories available on many public radio stations, Outright expanded in 2000 to six 30-minute shows and then in 2001 to five one-hour installments.
Outright Development will test and review the source code to ensure that the iPhone or iPad app is compliant with a new version of iOS.
Typically, the testator would provide in the will that the residence pass outright to his surviving spouse or other relative.
At his death, he leaves 49% of that stock outright to his wife, W, and 51% of it to a QTIP trust for her benefit.
In fact, two recent letter rulings have held that a QTIP's fractional interest in property must be aggregated with a fractional interest in the same property held by the decedent outright for valuation purposes (see TAMs 9550002 and 9608001).
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