The IRS noted that the
CRUT was not exempt from tax under Sec.
Consequently, Schaefer's estate was required to use an annual distribution amount of 11% (for
CRUT 1) or 10% (for
CRUT 2) of the net FMV of the trust assets when valuing the remainder interests.
For instance, an otherwise permissible split-interest trust with a 1 percent unitrust amount must be increased to 5 percent (the statutory floor) to qualify as a
CRUT, but if the modification causes the date-of-death actuarial value of the charitable remainder interest to decrease by more than 5 percent, the reformation will not be qualified and a charitable deduction would be denied.
Acute inflammatory cells were limited to the wound surface and under
crut. Wound surface was covered with
crut including blood clot with fibrin, inflammatory cells and necrotic tissues debris.