Trust reformation respected for power-of-appointment and GST tax purposes

Plain-English summary

An irrevocable trust for six children and their descendants contained a drafting error that allowed annual withdrawal rights to lapse beyond the greater of $5,000 or five percent of trust assets. A state court reformed the trust retroactively to correct the scrivener’s error, contingent on a favorable IRS ruling. The IRS respected the reformation: no child would be treated as releasing a general power of appointment or making a taxable gift because of the withdrawal-right lapses, and no affected trust property would enter a child’s gross estate. The IRS also ruled that the parents and grandparents remained the transferors and that their generation-skipping transfer tax exemptions were automatically allocated to their respective split gifts.

Ruling snapshot

• Requests: Confirm the gift, estate, and GST tax effects of a retroactive judicial reformation limiting annual withdrawal-right lapses to the greater of $5,000 or five percent
• Outcome: approved; the reformation prevented taxable releases of general powers of appointment and preserved the intended transferors and automatic GST exemption allocations
• Key authorities: IRC §§ 2041, 2513, 2514, 2632, and 2652; Commissioner v. Estate of Bosch

Full text (IRS public release)

Internal Revenue Service                                       Department of the Treasury
                                                               Washington, DC 20224

Number: 201941013                                              Third Party Communication: None
Release Date: 10/11/2019                                       Date of Communication: Not Applicable
Index Number: 2041.00-00, 2501.00-00,
              2514.00-00, 2632.00-00                           Person To Contact:
                                                               ----------------, ID No. ------------------
----------------------------                                   Telephone Number:
----------------------------------                             ----------------------
 ----------------------------------------                      Refer Reply To:
                                                               CC:PSI:B04
                                                               PLR-135593-18
         In Re: ----------------------------                   Date:
                                                               May 29, 2019




LEGEND

Date 1                     =        ---------------------------
Settlor                    =        ------------------------------------------------------
Spouse                     =        -----------------------------------------------------
Trust                      =        -----------------------------------------------------------------
Child 1                    =        --------------------------------------------------
Child 2                    =        -----------------------------------------------
Child 3                    =        --------------------------------------------------
Child 4                    =        --------------------------------------------------
Child 5                    =        -----------------------------------------------
Child 6                    =        --------------------------------------------------
Trust 1                    =         ---------------------------------------------------------------------
                                    ------------------------
Trust 2                    =         ------------------------------------------------------------------
                                    ------------------------
Trust 3                    =         --------------------------------------------------------------------
                                    ------------------------
Trust 4                    =         ---------------------------------------------------------------------
                                    ------------------------
Trust 5                    =         ------------------------------------------------------------------
                                    ------------------------
Trust 6                    =        -------------------------------------------------------------------
                                    ------------------------
State                      =        --------------------
Grandfather                =        --------------------------------------------------------
Grandmother                =        ------------------------------------------------------
x                          =        ----------
y                          =        --------
Year 1                     =        -------

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Year 2                     =   -------
Year 3                     =   -------
Year 4                     =   -------
Attorney                   =   -------------------------
Date 2                     =   -----------------------
Date 3                     =   -------------------
Court                      =   ------------------------------------------------------------
Statute 1                  =   -----------------------------------------
Statute 2                  =   -----------------------------------------



Dear ------------------:

This letter responds to the letter dated December 7, 2018, and subsequent
correspondence, submitted by your authorized representative, requesting rulings on the
gift, estate, and generation-skipping transfer (GST) tax consequences of the proposed
reformation of an irrevocable trust.

FACTS

The facts submitted and the representations made are as follows:

On Date 1 (a date after December 31, 2000), Settlor executed an irrevocable trust,
Trust, with Spouse as Trustee, for the benefit of their six children, Child 1, Child 2,
Child 3, Child 4, Child 5, and Child 6, and their descendants. Pursuant to the terms of
Trust, six separate trusts, Trust 1, Trust 2, Trust 3, Trust 4, Trust 5, and Trust 6, were
established, one to benefit each child (collectively, the Children’s Trusts; individually, a
Child’s Trust). The Children’s Trusts are governed by the laws of State.

Under Paragraphs 1.02 and 2.01(2) of Trust, each child is the Primary Beneficiary of his
or her Child’s Trust. Property transferred to Trustee shall be allocated among the
Children’s Trusts equally between all of such trusts.

Paragraph 2.01(3) provides that during each Primary Beneficiary’s life, the Trustee shall
distribute all of the income of such beneficiary’s Child Trust to the Primary Beneficiary;
and may distribute such portion or all of the principal of such Child’s Trust, to or for the
support, maintenance, medical expenses, health and education of the Primary
Beneficiary, as the Trustee, in her sole and absolute judgment and discretion,
determines.

Under Paragraph 2.02(2), at the time of death of the Primary Beneficiary, such
Child’s Trust shall continue, in separate trust shares, per stirpes, for his or her lineal
descendants; and upon the death of each of such respective lineal descendants, then

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for such respective deceased lineal descendant’s lineal descendants, in separate trust
shares, per stirpes, for their respective lives; and so forth until such trusts terminate
under Paragraph 7.01.

Paragraph 7.01 provides that any trust created under Trust, if not otherwise fully
terminated, shall terminate fully and all principal and undistributed income shall be
distributed to the respective income beneficiary at the end of twenty-one years after the
death of the last to die of Settlor and all Primary Beneficiaries of the trusts created
under Trust.

Paragraph 7.02 provides, generally, that the Trustee may receive property from the
Settlor or any other person or persons, by lifetime gift, under a will or trust or from any
other source. With respect to additions during any calendar year from any donor, each
beneficiary may demand, for a period of thirty days immediately after each such initial
contribution and any additions during any calendar year from each donor, up to the
maximum amount allowable with respect to such donor as an annual exclusion for gift
tax purposes within §§ 2503 and 2513, payable in cash or in kind immediately upon
receipt by the Trustee of the demand in writing. Such payment shall be made from the
gift of that donor for that year or from property purchased with such gift. If any such
beneficiary is a minor at the time of such gift of any donor for that year, or if any such
beneficiary fails in legal capacity for any reason at such time, then such beneficiary’s
guardian may make such demand on behalf of said beneficiary, and the property
received pursuant to such demand shall be held by the guardian for the benefit of said
beneficiary. The Trustee shall give written notice of the receipt of any property by the
Trustee, to be held in trust hereunder, to all beneficiaries of the trust, or to the guardian
of any minor beneficiary or any other beneficiary who fails in legal capacity, within thirty
days of the receipt of such property.

Settlor transferred $x to each Child’s Trust in Year 1, Year 2, Year 3, and Year 4.
Settlor timely filed Forms 709, United States Gift (and Generation-Skipping Transfer)
Tax Returns, for Year 1, Year 2, Year 3, and Year 4. On each Form 709, Settlor and
Spouse signified consent to treat all gifts made by Settlor in Year 1, Year 2, Year 3, and
Year 4 as having been made one-half by each spouse under § 2513. On each
Form 709 for Year 1, Year 2, and Year 3, the transfers of $x to each Child’s Trust were
incorrectly reported on Forms 709, Schedule A, Part 1-Gifts Subject Only to Gift Tax,
instead of Schedule A, Part 3-Indirect Skips. No affirmative allocation of GST
exemption was made to the transfers to each Child’s Trust. Furthermore, the automatic
allocation of the GST exemption was not reported on Schedule C, Computation of
Generation-Skipping Transfer Tax.

Grandfather transferred $y to each Child’s Trust in Year 1 and Year 2. Grandfather and
Grandmother timely filed Forms 709 for Year 1 and Year 2. On each Form 709,
Grandfather and Grandmother signified consent to treat all gifts made by Grandfather in
Year 1 and Year 2, as having been made one-half by each spouse under § 2513. On

PLR-135593-18                                4

each Form 709 for Year 1 and Year 2, the transfers of $y to each Child’s Trust were
incorrectly reported as an outright gift to each of Child 1 through Child 6, on Schedule A,
Part 1-Gifts Subject Only to Gift Tax, instead of a gift to each Child’s Trust on
Schedule A, Part 2-Direct Skips. No affirmative allocation of GST exemption was made
to the transfers to each Child’s Trust. Furthermore, Accountant left blank Schedule C of
Forms 709 for both Grandfather and Grandmother for Year 1 and Year 2.

Attorney drafted Trust. Settlor created and funded Trust relying on the advice of
Attorney. Based on affidavits of Settlor and Attorney, Settlor created Trust to provide for
his descendants of all generations, and to reduce the overall transfer taxes payable on
Trust assets by ensuring that the assets held in Trust would not be includible in a
Primary Beneficiary’s gross estate upon his or her death, and to minimize the amount
subject to GST tax by utilizing Settlor’s and Spouse’s GST exemption. Settlor also
intended to ensure that the Primary Beneficiary would avoid incurring federal gift and
estate tax in connection with a transfer to Trust.

The withdrawal provision in Paragraph 7.02 contains a drafting error. Each Primary
Beneficiary’s withdrawal right over the assets contributed to a Child’s Trust in any given
year is not limited to the greater of $5,000 or 5 percent of the value of the trust assets.
Accordingly, any lapse of a Primary Beneficiary’s withdrawal right would be treated as a
taxable transfer by that Primary Beneficiary under § 2514 to the extent that the property
that could have been withdrawn exceeds in value the greater of $5,000 or 5 percent of
the aggregate value of the assets subject to withdrawal. Moreover, each Primary
Beneficiary would become a transferor to his or her Child’s Trust for GST tax purposes
with respect to the portion of the Child’s Trust constituting a gift by the Child, thereby
preventing (i) an effective deemed allocation of GST exemption under § 2632(c) by
Settlor and Spouse with respect to Settlor’s transfers to that Child’s Trust for each of
Year 1, Year 2, Year 3, and Year 4; and (ii) an effective deemed allocation of GST
exemption under § 2632(b) by Grandfather and Grandmother with respect to
Grandfather’s transfer to that Child’s Trust for each of Year 1 and Year 2. In addition,
the portion of each Child’s Trust relating to the lapsed withdrawal right in excess of
$5,000 or 5 percent of the value of the trust assets would be included in the Primary
Beneficiary’s gross estate for estate tax purposes.

The error was discovered when Settlor engaged new estate planning counsel who
reviewed Settlor’s current estate plan, including Trust. Settlor was informed of the
drafting error that defeated the intent of the Settlor in establishing Trust. On Date 2,
Trustee filed a petition in State Court requesting judicial reformation of the erroneous
provision of Paragraph 7.02, effective as of the date Trust was originally created. On
Date 3, State Court issued an order reforming Trust to eliminate the scrivener’s error
retroactive to the date of Trust’s creation. The order is contingent upon the issuance of
a favorable private letter ruling by the Internal Revenue Service.

PLR-135593-18                                  5

As reformed, Trust limits the annual lapse of each Primary Beneficiary’s withdrawal right
to the greater of $5,000 or 5 percent of the value of the trust assets.
You have requested the following rulings:

1. As a result of the reformation, no Child will be deemed to have released a general
power of appointment within the meaning of §§ 2514 and 2041 by reason of the lapse of
any right of withdrawal held by the Child with respect to any transfers to his or her
Child’s Trust. Accordingly, no Child will be deemed to have made a taxable gift under
§ 2514 to his or her Child’s Trust and no part of his or her Child’s Trust will be included
in his or her gross estate under § 2041.

2. As a result of the reformation, the only transferors to each Child’s Trust for GST tax
purposes are Settlor, Spouse, Grandfather and Grandmother.

3. As a result of the reformation, each of Settlor’s and Spouse’s GST exemption is
automatically allocated to one-half of the transfers by Settlor to each Child’s Trust and
each of Grandfather’s and Grandmother’s GST exemption is automatically allocated to
one-half of the transfers by Grandfather to each Child’s Trust.

LAW AND ANALYSIS

Ruling 1

Section 2001(a) provides that a tax is imposed on the transfer of the taxable estate of
every decedent who is a citizen or resident of the United States.

Section 2033 provides, generally, that the value of the gross estate shall include the
value of all property to the extent of the interest therein of the decedent at the time of his
death.

Section 2041(a)(2) provides that the value of the gross estate includes the value of all
property to the extent of any property with respect to which the decedent has at the time
of his death a general power of appointment created after October 21, 1942, or with
respect to which the decedent has at any time exercised or released such a power of
appointment by a disposition which is of such nature that if it were a transfer of property
owned by the decedent, such property would be includible in the decedent’s gross
estate under §§ 2035 to 2038, inclusive. For purposes of § 2041(a)(2), the power of
appointment shall be considered to exist on the date of the decedent’s death even
though the exercise of the power is subject to a precedent giving of notice or even
though the exercise of the power takes effect only on the expiration of a stated period
after its exercise, whether or not on or before the date of the decedent’s death notice
has been given or the power has been exercised.

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Section 2041(b)(1) provides that for purposes of § 2041(a), the term “general power of
appointment” means a power which is exercisable in favor of the decedent, his estate,
his creditors, or the creditors of his estate.

Section 2041(b)(2) provides that the lapse of a power of appointment created after
October 21, 1942, during the life of the individual possessing the power shall be
considered a release of such power. The preceding sentence shall apply with respect
to the lapse of powers during any calendar year only to the extent that the property,
which could have been appointed by exercise of such lapsed powers, exceeded in
value, at the time of such lapse, the greater of the following amounts: (A) $5,000, or
(B) 5 percent of the aggregate value, at the time of such lapse, of the assets out of
which, or the proceeds of which, the exercise of the lapsed powers could have been
satisfied.

Section 2501(a)(1) provides, generally, that a tax is imposed for each calendar year on
the transfer of property by gift by any individual, resident or nonresident. Section
2511(a) provides that the gift tax shall apply whether the transfer is in trust or otherwise,
whether the gift is direct or indirect, and whether the property is real or personal,
tangible or intangible.

Section 2514(b) provides that the exercise or release of a general power of appointment
created after October 21, 1942, shall be deemed a transfer of property by the individual
possessing such power.

Section 2514(c) provides that for purposes of § 2514, the term “general power of
appointment” means a power which is exercisable in favor of the individual possessing
the power, his estate, his creditors, or the creditors of his estate.

Section 2514(e) provides that the lapse of a power of appointment created after
October 21, 1942, during the life of the individual possessing the power shall be
considered a release of such power. The rule of the preceding sentence shall apply
with respect to the lapse of powers during any calendar year only to the extent that the
property which could have been appointed by exercise of such lapsed powers exceeds
in value the greater of the following amounts: (1) $5,000, or (2) 5 percent of the
aggregate value of the assets out of which, or the proceeds of which, the exercise of the
lapsed powers could be satisfied.

In Commissioner v. Estate of Bosch, 387 U.S. 456 (1967), the Court considered
whether a state trial court’s characterization of property rights conclusively binds a
federal court or agency in a federal estate tax controversy. The Court concluded that
the decision of a state trial court as to an underlying issue of state law should not be
controlling when applied to a federal statute. Rather, the highest court of the state is the
best authority on the underlying substantive rule of state law to be applied in the federal
matter. If there is no decision by that court, then the federal authority must apply what it

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finds to be state law after giving “proper regard” to the state trial court’s determination
and to relevant rulings of other courts of the state. In this respect, the federal agency
may be said, in effect, to be sitting as a state court.

State Statute 1 provides, in part, that a proceeding to approve or disapprove a proposed
modification or termination of a trust, may be commenced by a trustee or a beneficiary.

State Statute 2 provides, in part, that the court may reform the terms of a trust, even if
unambiguous, to conform the terms to the settlor’s intention if it is proved by clear and
convincing evidence that the settlor’s intent or the terms of the trust were affected by a
mistake of fact or law.

In this case, an examination of the relevant trust instruments, affidavits, and
representations of the parties indicate that the original terms of Paragraph 7.02,
resulting from a scrivener’s error, were contrary to the intent of Settlor. The purpose of
the reformation is to correct the scrivener’s error, not to alter or modify the trust
instrument. Accordingly, based on the facts presented and the representations made,
we conclude that as a result of the reformation of Trust, each of Settlor’s children,
Child 1 through Child 6, does not possess general powers of appointment over the
assets of his or her respective Child’s Trust, except to the extent of each Child’s
withdrawal right under the reformed trust instrument. As a result of the reformation, no
Child will be deemed to have released a general power of appointment within the
meaning of §§ 2514 and 2041 by reason of the lapse of any right of withdrawal held by
the Child with respect to any transfers to his or her Child’s Trust. Accordingly, no Child
will be deemed to have made a taxable gift under § 2514 to his or her Child’s Trust and
no part of his or her Child’s Trust will be included in his or her gross estate under
§ 2041.

Rulings 2 and 3

Section 2513(a)(1) provides, generally, that a gift made by one spouse to any person
other than the donor’s spouse is considered for purposes of the gift tax as made
one-half by the donor and one-half by the donor’s spouse, but only if at the time of the
gift each spouse is a citizen or resident of the United States.

Section 25.2513-1(b)(4) of the Gift Tax Regulations provides that the consent is
effective only if both spouses signify their consent to treat all gifts made to third parties
during that calendar period by both spouses while married to each other as having been
made one-half by each spouse. Such consent, if signified with respect to any calendar
period, is effective with respect to all gifts made to third parties during such calendar
period except, in part, if one spouse transferred property in part to his or her spouse and
in part to third parties, the consent is effective with respect to the interest transferred to
third parties only insofar as such interest is ascertainable at the time of the gift and
severable from the interest transferred to his spouse.

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Section 25.2513-1(b)(5) provides that the consent applies alike to gifts made by one
spouse alone and to gifts made partly by each spouse, provided such gifts were to third
parties and do not fall within any of the exceptions set forth in § 25.2513-1(b)(1) through
(b)(4). The consent may not be applied only to a portion of the property interest
constituting such gifts. If the consent is effectively signified on either the husband’s
return or the wife’s return, all gifts made by the spouses to third parties (except as
described in subparagraphs (1) through (4) of this paragraph), during the calendar
period will be treated as having been made one-half by each spouse.

Section 2601 imposes a tax on every generation-skipping transfer, which is defined
under § 2611 as a taxable distribution, a taxable termination, and a direct skip.

Section 2602 provides that the amount of the GST tax is determined by multiplying the
taxable amount by the applicable rate.

Section 2641(a) provides that the term “applicable rate” means, with respect to any
GST, the product of the maximum federal estate tax rate and the inclusion ratio with
respect to the transfer.

Under § 2642(a)(1), the inclusion ratio with respect to any property transferred in a GST
is the excess (if any) of 1 over the applicable fraction. The applicable fraction, as
defined in § 2642(a)(2), is a fraction, the numerator of which is the amount of the GST
exemption under § 2631 allocated to the trust (or to property transferred in a direct
skip), and the denominator of which is the value of the property transferred to the trust
(or involved in the direct skip), reduced by the sum of any federal estate tax or state
death tax actually recovered from the trust attributable to such property, and any
charitable deduction allowed under § 2055 or § 2522 with respect to such property.

Section 2631(a) provides that, for purposes of determining the inclusion ratio, every
individual shall be allowed a GST exemption amount which may be allocated by such
individual (or his executor) to any property with respect to which such individual is the
transferor. Section 2631(b) provides that any allocation under § 2631(a), once made,
shall be irrevocable.

Section 2652(a)(1) provides, in part, that the term “transferor” means in the case of any
property subject to the tax imposed by chapter 12, the donor. Section 26.2652-1(a)(1)
of the Generation-Skipping Transfer Tax Regulations provides that the individual with
respect to whom property was most recently subject to federal estate or gift tax is the
transferor of that property for purposes of chapter 13.

Under § 26.2652-1(a)(5), Example 5, T transfers $10,000 to a new trust providing that
the trust income is to be paid to T’s child, C, for C’s life and, on the death of C, the trust
principal is to be paid to T’s grandchild, GC. The trustee has discretion to distribute

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principal for GC’s benefit during C’s lifetime. C has a right to withdraw $10,000 from the
trust for a 60-day period following the transfer. Thereafter, the power lapses. C does
not exercise the withdrawal right. The transfer by T is subject to federal gift tax because
a gift tax is imposed under § 2501(a) (without regard to exemptions, exclusions,
deductions, and credits) and, thus, T is treated as having transferred the entire $10,000
to the trust. On the lapse of the withdrawal right, C becomes a transferor to the extent
C is treated as having made a completed transfer for purposes of chapter 12.
Therefore, except to the extent that the amount with respect to which the power of
withdrawal lapses exceeds the greater of $5,000 or 5 percent of the value of the trust
property, T remains the transferor of the trust property for purposes of chapter 13.

Section 2652(a)(2) provides that if, under § 2513, one-half of a gift is treated as made
by an individual and one-half of such gift is treated as made by the spouse of such
individual, such gift shall be so treated for purposes of this chapter.

Section 26.2652-1(a)(4) provides that in the case of a transfer with respect to which the
donor’s spouse makes an election under § 2513 to treat the gift as made one-half by the
spouse, the electing spouse is treated as the transferor of one-half of the entire value of
the property transferred by the donor, regardless of the interest the electing spouse is
actually deemed to have transferred under § 2513. The donor is treated as the
transferor of one-half of the value of the entire property.

Section 2632(a)(1) provides that any allocation by an individual of his or her GST
exemption under § 2631(a) may be made at any time on or before the date prescribed
for filing the estate tax return for such individual’s estate (determined with regard to
extensions), regardless of whether such a return is required to be filed.

Under § 2632(b)(1), if an individual makes a direct skip transfer during his or her
lifetime, any unused portion of such individual’s GST exemption is automatically
allocated to the property transferred to the extent necessary to make the inclusion ratio
zero. Under § 2612(c)(1), the term “direct skip” means a transfer subject to tax imposed
by chapter 11 or 12 of an interest in property to a skip person.

Section 26.2632-1(b)(1)(ii) provides, in part, that an automatic allocation of GST
exemption is effective as of the date of the transfer to which it relates. A Form 709 need
not be filed to report an automatic allocation.

Section 2632(c)(1) provides that if any individual makes an indirect skip during such
individual’s lifetime, any unused portion of such individual’s GST exemption shall be
allocated to the property transferred to the extent necessary to make the inclusion ratio
for such property zero.

Section 2632(c)(3)(A) provides that for purposes of § 2632(c), the term “indirect skip”
means any transfer of property (other than a direct skip) subject to the tax imposed by

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chapter 12 made to a GST trust. Section 2632(c)(3)(B) provides, in part, that the term
“GST trust” means a trust that could have a generation-skipping transfer with respect to
the transferor unless the exceptions enumerated in (i) through (vi) apply.

Section 2642(b)(1)(A) provides, in part, that, except as provided in § 2642(f), if the
allocation of the GST exemption to any transfers of property is made on a gift tax return
filed on or before the date prescribed by § 6075(b) for such transfer or is deemed to be
made under § 2632(b)(1) or (c)(1), the value of such property for purposes of § 2642(a)
shall be its value as finally determined for purposes of chapter 12 (within the meaning of
§ 2001(f)(2)).

In this case, each Child’s Trust is a GST Trust for purposes of § 2632(c). Settlor and
Spouse timely filed Forms 709 for Year 1, Year 2, Year 3, and Year 4, signifying their
consent to treat the gifts made in each of Year 1, Year 2, Year 3, and Year 4, to each
Child’s Trust as having been made one-half by each spouse under § 2513.
Accordingly, under § 2652(a)(2), Settlor and Spouse will be treated as the transferor of
one-half of the value of the entire property transferred to each Child’s Trust in Year 1,
Year 2, Year 3, and Year 4. Based on the facts presented and the representations
made, we rule that the automatic allocation rules under § 2632(c)(1) apply to allocate
Settlor’s and Spouse’s GST exemption to one-half of the transfers of property made to
each Child’s Trust in each of Year 1, Year 2, Year 3, and Year 4.

Grandfather and Grandmother timely filed Forms 709 for Year 1 and Year 2, signifying
their consent to treat the gifts made in each of Year 1 and Year 2 to each Child’s Trust
as having been made one-half by each spouse under § 2513. Accordingly, under
§ 2652(a)(2), Grandfather and Grandmother will be treated as the transferor of one-half
of the value of the entire property transferred to each Child’s Trust in Year 1 and Year 2.
Based on the facts presented and the representations made, we rule that the automatic
allocation rules under § 2632(b)(1) apply to allocate Grandfather’s and Grandmother’s
GST exemption to one-half of the transfers of property made to each Child’s Trust in
each of Year 1 and Year 2.

In accordance with the Power of Attorney on file with this office, a copy of this letter is
being sent to your authorized representatives.

Except as expressly provided herein, no opinion is expressed or implied concerning the
tax consequences of any aspect of any transaction or item discussed or referenced in
this letter.

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This ruling is directed only to the taxpayer requesting it. Section 6110(k)(3) of the Code
provides that it may not be used or cited as precedent.


                                         Sincerely,


                                         Lorraine E. Gardner
                                         Lorraine E. Gardner
                                         Senior Counsel, Branch 4
                                         Office of the Associate Chief Counsel
                                         (Passthroughs & Special Industries)



Enclosures (2)
      Copy for §6110 purposes
      Copy of this letter


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