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3. Retention of Life Income Interest Required.

Each donor transferring property to the Pool shall retain for himself for life an income interest in the property transferred, or create an income interest in such property for the life of one or more named beneficiaries, each of whom must be living at the time of the transfer of the property to the Pool by the donor. Such income interest shall be represented by units of participation in the Pool. In the event more than one beneficiary of the income interest is named, such beneficiaries may enjoy their shares of income concurrently, consecutively or both concurrently and consecutively. The Institution may also be designated as one of the beneficiaries of the income interest. The donor need not retain or create a life interest in all the income


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from the property transferred to the Pool provided any income not payable to an income beneficiary under the terms of the instrument of transfer is contributed to, and within the taxable year of the Pool in which it is received is paid to, the Institution.