Comment on FR Doc # E9-10003

In Prop Reg 20.2036-1(c), Example 1, it may be desirable to clarify further clarify that the phrase “less the present value of C’s outstainding life estate” refers only to the 1/2 income interest that is being treated for analytical purposes as being attributable to a “remaining 50 percent of trust corpus". For example (but I’m sure this can be improved upon) the bracketed language might be added to the following quote from the prop reg: "Fifty percent of the value of the trust corpus is includible in D's gross estate under section 2036(a)(1) because, under the terms of the trust, D retained the right to receive one-half of the trust income for D's life. In addition, the value of the remaining 50 percent of the trust corpus, less the present value of C's outstanding life estate [in that 50 percent of trust corpus], also is includible in D's gross estate under section 2036(a)(1), because D retained the right to receive all of the trust income for such time as D survived C."