Valuation of life interest: prescribed method ties market value to average annual income with limited adjustments and caps. Valuation of life interest links market value to the average annual income from the life interest multiplied by an actuarial factor derived from the annual premium for whole-life assurance and an interest-rate term; definitions limit average-income computation to recent years net of collection expenses with a capped deduction; the tax officer may increase valuation for uninsurable lives, and the life-interest value cannot exceed the market value of the trust corpus.
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Provisions expressly mentioned in the judgment/order text.
Valuation of life interest: prescribed method ties market value to average annual income with limited adjustments and caps.
Valuation of life interest links market value to the average annual income from the life interest multiplied by an actuarial factor derived from the annual premium for whole-life assurance and an interest-rate term; definitions limit average-income computation to recent years net of collection expenses with a capped deduction; the tax officer may increase valuation for uninsurable lives, and the life-interest value cannot exceed the market value of the trust corpus.
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