11. Unit Plan of Allocation of Income to Beneficiary.
Every income interest retained or created in property transferred
to the Pool shall be assigned a proportionate share
of the annual income earned by the Pool, such share or units
of participation being based on the fair market value of such
property on the date of transfer as provided in this paragraph.
On each transfer of property by a donor to the Pool, there
shall be assigned to the beneficiary or beneficiaries of the
income interest retained or created in such property the number
of units of participation equal to the number obtained by
dividing the fair market value of the property transferred by
the fair market value of a unit in the Pool immediately before
such transfer. The fair market value of a unit in the Pool
immediately before the transfer shall be determined by dividing
the fair market value of all property in the Pool at such time
by the number of units in the Pool. All units in the Pool
always shall have equal value. The amount of the income allocated
to each unit of participation in the Pool shall be
determined by dividing the income of the Pool for the taxable
year by the outstanding number of units in the Pool at the end
of such year, except that income shall be allocated to units
outstanding during only part of such year by taking into consideration
the period of time such units are outstanding during
such year.
