H and W enter Sample Clauses

H and W enter into a written agreement relative to their marital and property rights that requires W to transfer property to an irrevocable trust, the terms of which provide that the income of the trust will be paid to H for 10 years. On the expira- tion of the 10-year term, the trust is to ter- minate and the trust corpus is to be paid to W. H and W divorce within two years after the agreement is entered into. Pursuant to section 2516, the transfer to H would other- wise be deemed to be for full and adequate consideration. Section 2702 does not apply to the acquisition of the term interest by H be- cause no member of H’s family acquired an interest in the property in the same trans- action or series of transactions. The result would not be the same if, on the termination of H’s interest in the trust, the trust corpus were distributable to the children of H and W rather than W. [T.D. 8395, 57 FR 4269, Feb. 4, 1992]
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