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SUBCHAPTER J i (MEMORANDUM 3, August 26, 1981)

handle is hein.ali/aliftp0453 and id is 1 raw text is: THIS DRAFT IS PRIVATE AND CONFIDENTIAL
(Not to be sold. offered for sale, or otherwise published)
The American Law Institute
Menorandum No. 3
Subjects Covered:
When the Net Taxable Income of a Trust is Taxable at the Marginal
Income Tax Rate of the Creator of the Trust
Taxation of the Net Taxable Income of a Trust That is Not Taxable at
the Marginal Income Tax Rate of the Creator of the Trust
Income Taxation of an Estate
Submitted to the Consultants for consideration at their meeting
on September 11 (at 10:00 a.m.), 12, and 13, 1981, at the ALI Conference Center,
4025 Chestnut Street, Philadelphia, Pennsylvania
August 26, 1981
The Executive Office
4025 Chestnut Street
Philadelphia, PA 19104
*This is a preliminary draft submitted on a private and confidential basis to a limited group for the sole
purpose of study and criticism. It has not been promulgated or approved by the Council or the
members of The American Law Institute,
As an unpublished document intended for internal use, this draft should not be generally circulated or
distributed, nor should it be quoted from or cited or its substance disclosed in any public address or

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