Grantor's power to substitute property may not require inclusion of the property in the grantor's gross estate. There has long been concern that a grantor's power to substitute property of a trust, which may be used to render the trust a grantor trust under Internal Revenue Code Section 675, may cause the trust property to be includible in the grantor's estate under IRC Sections 2036 or 2038. In Revenue Ruling 2008-22, 2008-16 IRB 796 (April, 17, 2008), the Internal Revenue Service
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