Full text
there shall be included in computing the trust’s income for its first taxation year, if any, that begins after the exemption-end time the amount determined by the formula D − E − F where D is the sum of the fair market value of all of the property held by the trust at the exemption-end time the total of all payments made out of or under the trust after the holder’s death and at or before the exemption-end time, E is the sum of the total of all amounts each of which is an amount determined for B in paragraph (b), and the total of all amounts included in a taxpayer’s income under paragraph (b) in respect of the trust, and F is the fair market value of all of the property held by the trust immediately before the holder’s death.