Corporate/trust instrument (EFTA01303352)

ATTACHMENT TO PETITION FOR ADVISORY OPINION IC rowL - uP cfs flicicivrretd- OinsTA w York - ar - •orni AD-1 .8 4. The petitioner submits the following statement of facts as the basis for the requested advisory opinion: Facts as the basis for the Advisor\ Oninion Petitioner (the "Senior-) created an irrevocable trust (the "Trust") pursuant to a trust agreement (the "Trust Agreement") between the Trustees and the Settlor. The Senior is deemed to own the Trust property for Federal and N