Leitman, Siegal & Payne, PC

Leitman, Siegal & Payne, PC Founded in 1976, Leitman, Siegal & Payne, PC, is a full-service, business-oriented law firm.

"No representation is made that the quality of the legal services to be performed is greater than the quality of legal services performed by other lawyers."

01/17/2024

FINANCIAL STRATEGIES FOR YOUR LIVES AND BUSINESSES
By Jackson M. Payne

OUR NEWSLETTERS

This month marks the 32nd anniversary of my newsletters to you, our clients and friends. And while this is my last monthly newsletter, I plan to continue to write whenever significant developments may have an impact on you and your family or business.

In closing, I hope my newsletters over the last three decades have been beneficial, and moving forward, I want you to know that we remain committed to helping you in any way we can whenever the need arises.

QUALIFIED PERSONAL RESIDENCE TRUSTS

A special kind of irrevocable trust can be used to transfer your residence to your children at a significantly reduced gift tax cost and with no estate tax, yet allow you to continue to live in the residence for as long as you wish. This special type of trust is known as a qualified personal residence trust (QPRT). Here's how it works.

During your lifetime, you transfer your residence to the trustee, who can be yourself. The trustee must allow you to continue to use the residence rent-free for a fixed number of years specified in the trust instrument (the "fixed term"), which should be a term you are likely to survive. During the fixed term, you will continue to pay mortgage expenses, real estate taxes, insurance, and expenses for maintenance and repairs, and will continue to deduct mortgage interest and real estate taxes on your individual income tax return. When the fixed term ends, the residence is distributed to your children, or remains in further trust for them.

Even after the fixed term ends, you can continue to use the residence in one of two ways. First, rather than immediately distributing the residence to your children, the residence can be retained in trust for your spouse's lifetime, thus assuring that the residence is available to you. Second, you can enter into a lease with your children which will allow you to live in the residence for as long as you wish. (If you do so, however, you must pay fair market value rent to your children after the fixed term ends in order to keep the residence from being subject to estate tax on your death.)

Although your transfer of the residence to the trust is a taxable gift, you are allowed to subtract, from the fair market value of the residence, the value of your right to live rent-free in the residence for the fixed term. Thus, the amount of the taxable gift will usually be substantially less than the fair market value of the residence. If the amount of the gift is less than your available exclusion from the gift tax ($12,920,000 in 2023), reduced by amounts allowed for gifts in previous years), no gift tax will be due as a result of your gift to the trust.

If you survive the fixed term of the QPRT, the value of the residence will not be included in your estate for estate tax purposes. Even if you don't survive the fixed term, the estate tax consequences will be no worse than they would have been if you hadn't created the trust in the first place.

A QPRT is an effective way to remove a residence's value from your estate at a greatly reduced gift tax cost. However, you should also take into consideration whether holding your residence so that it is includible in your estate for a step basis is beneficial.

PLEASE VISIT OUR WEBSITE AT LSPPC.COM.

The Alabama State Bar requires the following disclosure: No representation is made that the quality of legal services to be performed is greater than the quality of legal services performed by other lawyers.

IRS Circular 230 Disclosure: To the extent this message contains tax advice, the U.S. Treasury Department requires me to inform you that any such advice, whether in the body of the message or in any attachment, is not intended or written by my firm to be used, and cannot be used by any taxpayer, for the purpose of avoiding any penalties that may be imposed under the Internal Revenue Code. Advice from my firm relating to tax matters may not be used in promoting, marketing or recommending any entity, investment plan or arrangement to any taxpayer.

Copyright © 2024 Leitman Siegal & Payne, P.C. All rights reserved.

12/15/2023

FINANCIAL STRATEGIES FOR YOUR LIVES AND BUSINESSES
By Jackson M. Payne

HAPPY HOLIDAYS

As always, our staff joins with me in wishing you the very best for the holiday season. We have so much to be thankful for and are truly blessed in having strong client and professional relationships. For those who have stood by us over the years, we simply, but most sincerely, say thank you. You are the greatest and we welcome the opportunity to serve you in the upcoming year and beyond.

CRUMMEY TRUSTS FOR GIFTS TO CHILDREN

As I'm sure you know, everyone can give away up to the gift tax annual exclusion amount each year to each of an unlimited number of donees, free of gift and generation-skipping transfer tax.

Where the donee is a minor, many parents and grandparents make their annual gifts to a custodial account under the Uniform Transfers to Minors Act (UTMA). A UTMA account works well and is easy to create and maintain. However, it has one major defect: when the child (or grandchild) reaches age 21, the beneficiary can do whatever he or she wants with the money in his or her custodial account. If, for example, the beneficiary wants to buy a sports car instead of going to college, there is nothing that you can do about it.

Few parents wish their children (or grandchildren) to receive significant amounts of cash at age 21. Fortunately, there is a special kind of trust that avoids this problem. It's called a "Crummey" trust, after a court case that paved the way for the use of this kind of trust. With a Crummey trust, the property can remain in trust for as long as you wish without forfeiting the gift tax annual exclusion. Thus, you can transfer property to remain in a Crummey trust for the beneficiary's entire lifetime or until an appropriate age (e.g., age 30) or event (e.g., graduation from college). You decide how the money is to be used and how much the beneficiary can receive.

There's one catch to a Crummey trust: annual contributions you make to the trust won't qualify for the gift tax annual exclusion unless you notify the beneficiary that you've made the contributions and give him or her a limited period of time (usually 30 days) in which he or she can withdraw the contributions from the trust. It's usually understood that the beneficiary won't exercise his or her right to withdraw the contributions but will let them remain in the trust. However, that expectation should always remain unwritten because, if there's any evidence of it, IRS will use that evidence to say that the beneficiary didn't really have a power of withdrawal. If the beneficiary violates the unwritten understanding by withdrawing property from the trust, there's nothing you can do about it, except to show your displeasure by not making any further contributions to that beneficiary's trust.

QTIPING AN IRA

If you're like many people, you have substantial sums invested in individual retirement accounts (IRAs). In fact, it's not unusual for a rollover IRA - one holding distributions from a qualified retirement plan - to be a family's most important asset.

While owning these assets may make you rich on paper, this wealth could go up in smoke if the IRA isn't handled correctly. If you take the money out of the IRA, you must pay income tax on it. If you leave it in the IRA until death, the date-of-death account balance will be subject to estate tax. Plus, your beneficiaries will still have to pay income tax on what's left.

By designating a qualified terminable interest property (QTIP) trust as the beneficiary of your IRA, you can postpone paying estate taxes on the property until your spouse's death and provide for your spouse during his or her lifetime. And you can do this while protecting the property for ultimate distribution to your children.

An IRA-to-QTIP trust arrangement can minimize your taxes and meet your non-tax objectives. But, the arrangement must be carefully structured, or your spouse and children may lose the benefit of income tax and estate tax deferral. Payout of an IRA must comply with technical provisions of the income tax law. QTIP trusts must satisfy estate tax requirements. Meshing the two sets of rules is complicated.

PLEASE VISIT OUR WEBSITE AT LSPPC.COM.

The Alabama State Bar requires the following disclosure: No representation is made that the quality of legal services to be performed is greater than the quality of legal services performed by other lawyers.

IRS Circular 230 Disclosure: To the extent this message contains tax advice, the U.S. Treasury Department requires me to inform you that any such advice, whether in the body of the message or in any attachment, is not intended or written by my firm to be used, and cannot be used by any taxpayer, for the purpose of avoiding any penalties that may be imposed under the Internal Revenue Code. Advice from my firm relating to tax matters may not be used in promoting, marketing or recommending any entity, investment plan, or arrangement to any taxpayer.

Copyright © 2023 Leitman Siegal & Payne, P.C. All rights reserved.

11/15/2023

FINANCIAL STRATEGIES FOR YOUR LIVES AND BUSINESSES
By Jackson M. Payne

THE DECEASED SPOUSAL UNUSED EXCLUSION (DSUE) AMOUNT (THE PORTABILITY RULES)

Here is a summary of the "portability" rules, which apply to the unused estate tax exclusion amount of a deceased spouse. A taxpayer can elect to transfer at death any unused exclusion to his or her surviving spouse. The amount received by the surviving spouse is called the deceased spousal unused exclusion, or DSUE, amount.

Because the unused estate tax exclusion of the deceased spouse can be carried over and used by the estate of the surviving spouse, this is described as providing for the "portability" of the estate tax exclusion amount between spouses. The executor of the decedent's estate must elect this portability of the DSUE amount, and if that election is made, the surviving spouse can apply the DSUE amount received from the estate of his or her last deceased spouse (see below) against any tax liability arising from subsequent lifetime gifts and transfers at death.

Any applicable exclusion amount that remains unused as of the death of the first spouse to die is generally available for use by the surviving spouse (as long as the election is made), as an addition to the surviving spouse's basic exclusion amount (which, in 2023, is $12,920,000). The DSUE amount is determined as of the year of death of the first spouse to die, and is not adjusted for inflation that occurs after that spouse dies, even though the basic exclusion amount of the surviving spouse is adjusted annually.

The last deceased spouse is the most recently deceased person who was married to the surviving spouse at the time of that person's death. The identity of the last deceased spouse is determined as of the day a taxable gift is made, or in the case of a transfer at death, the date of the surviving spouse's death. Remarriage does not affect the designation of the last deceased spouse and does not prevent the surviving spouse from applying the DSUE amount to taxable transfers.

To elect portability of the DSUE amount, if any exists, the executor must timely and completely file a Form 706 (the estate tax return). The filing requirement applies to all estates of decedents choosing to elect portability of the DSUE amount, regardless of the size of the estate, so an estate that would normally not have to file an estate tax return (because the estate is less than the estate exclusion amount that is applicable in the year of death) must file a return to elect portability. Taxpayers can also opt out of portability on a timely and completely filed estate tax return.

PLEASE VISIT OUR WEBSITE AT LSPPC.COM.

The Alabama State Bar requires the following disclosure: No representation is made that the quality of legal services to be performed is greater than the quality of legal services performed by other lawyers.

IRS Circular 230 Disclosure: To the extent this message contains tax advice, the U.S. Treasury Department requires me to inform you that any such advice, whether in the body of the message or in any attachment, is not intended or written by my firm to be used, and cannot be used by any taxpayer, for the purpose of avoiding any penalties that may be imposed under the Internal Revenue Code. Advice from my firm relating to tax matters may not be used in promoting, marketing or recommending any entity, investment plan or arrangement to any taxpayer.

Copyright © 2023 Leitman, Siegal & Payne, P.C. All rights reserved.

10/16/2023

FINANCIAL STRATEGIES FOR YOUR LIVES AND BUSINESSES
By Jackson M. Payne

INHERITED IRAs HAVE NEW RULES

The Internal Revenue Service, under recently issued guidance, is allowing people who inherited an individual retirement account after 2019 to skip a required minimum distribution this year.

There has been confusion surrounding the rules for inherited IRAs ever since the Secure Act of 2019 eliminated the so-called “stretch IRA” for most non-spouse beneficiaries.

The old rules had allowed beneficiaries of inherited IRAs to stretch their required minimum distributions over their own lifetimes, permitting decades of tax-free or tax-deferred growth in some cases.

Under the Secure Act of 2019, most non-spouse beneficiaries must now empty their inherited IRA by the end of the 10th year following the original owner’s death. When the law was first passed, many interpreted it to mean that all the money could be withdrawn in year 10 if so desired.

Yet in early 2022, the IRS proposed stricter rules that would apply to someone who inherited an IRA from a person who had already begun taking RMDs; in that case, the recipient must continue taking distributions on an annual schedule.

In other words, if the RMD tap had already been turned on, it couldn’t be turned off following the original owner’s death, and beneficiaries had to keep withdrawing every year and paying income tax on the amount withdrawn.

Due to the lateness of that proposal and the general confusion about the rules, the IRS recently waived that annual requirement for now, though in many cases, the 10-year rules still applies for IRAs inherited after 2019. Here’s what the most recent IRS guidance means for you:

What if I inherited an IRA before 2020?

You are grandfathered into the co-called stretch IRA rules that applied before the law’s passage. The relief announced by the IRS also doesn’t apply to you, so if you have an RMD scheduled for this year, you must take it.

What if I inherited an IRA from my spouse?

None of the changes apply to spouses, who enjoy far more flexibility when inheriting IRAs. You can roll over your spouse’s IRA into your own retirement account or keep it as an inherited account. Either way, you can stretch distributions based on your life expectancy, not the 10 years.

Are there any other beneficiaries who can take RMDs based on their own life expectancy?

Yes. There are a few others. They include: beneficiaries who are no more than 10 years younger than the original IRA owner; those who are chronically ill or disabled; and minor children—not grandchildren—of the original owner.

What if I inherited an IRA after 2019 from someone who had begun taking RMDs?

You don’t have to take an RMD this year, but keep an eye out for final regulations on the matter. The account will still have to be drained within 10 years, so more will have to come out in a shorter window.

What if I inherited an IRA from someone who had not begun taking RMDs?

The relief granted recently doesn’t apply to you, because you weren’t subject to the tougher RMD rules in the first place. However, you still must empty your inherited IRA by the end of the tenth year following the original owner’s death.

PLEASE VISIT OUR WEBSITE AT LSPPC.COM.

The Alabama State Bar requires the following disclosure: No representation is made that the quality of legal services to be performed is greater than the quality of legal services performed by other lawyers.

IRS Circular 230 Disclosure: To the extent this message contains tax advice, the U.S. Treasury Department requires me to inform you that any such advice, whether in the body of the message or in any attachment, is not intended or written by my firm to be used, and cannot be used by any taxpayer, for the purpose of avoiding any penalties that may be imposed under the Internal Revenue Code. Advice from my firm relating to tax matters may not be used in promoting, marketing or recommending any entity, investment plan, or arrangement to any taxpayer.

Copyright © 2023 Leitman, Siegal & Payne, P.C. All rights reserved.

09/15/2023

FINANCIAL STRATEGIES FOR YOUR LIVES AND BUSINESSES
By Jackson M. Payne

NET INVESTMENT INCOME TAX

Many Americans don’t know Uncle Sam has an extra tax on investment income for higher earners—at least until they owe it. This levy is called the net investment income tax, or NIIT for short. It’s a 3.8% surtax on a filer’s income from sources like interest, dividends and capital gains that applies if adjusted gross income or AGI, is above $200,000 for most single filers or $250,000 for most married couples.

It affects one-time spikes as well as recurring income, so taxpayers who typically earn less can owe it on a windfall. Although the 3.8% rate is low, the NIIT deserves a close look because even small taxes can affect investment decisions. And the NIIT’s reach is expanding.

When lawmakers enacted it to help fund the Obama-care health-coverage expansion, they chose not to adjust the $200,000/$250,000 thresholds for inflation to collect more tax.

(a) The 3.8% surtax applies to net capital gains on asset sales (including cryptocurrency), dividends, interest (including on CDs and bank accounts) and royalties, among other things. It also applies to net gains on the sale of a home above the exemption of $250,000 for single filers and $500,000 for joint filers. Rental income can be subject to the tax as well, unless it’s from an actively managed real estate business.

(b) Wages, pensions, Social Security payments and taxable retirement-plan payouts aren’t themselves subject to NIIT, but they can help trigger it as described below. Tax-free municipal-bond income is exempt as well. Income from actively managed businesses such as partnerships and S corporations doesn’t count either.

(c) Because investment income “stacks” on top of the filer’s other income, wages, IRA withdrawals and other taxable income can help push investment income over the NIIT threshold.

Strategies to Consider

Tax-deductible contributions to traditional IRAs, 401(k)s or Health Savings Accounts all help to lower AGI, which can reduce the surtax. By contrast, Schedule A deductions like mortgage interest, medical expenses and charitable donations don’t reduce NIIT as they don’t lower AGI.

For older taxpayers taking required IRA payouts who are charitably minded, making donations with Qualified Charitable Distributions from a traditional IRA can help. Donors can give up to $100,000 of IRA assets per year to one or more qualified charities and count the donations toward their required payouts, keeping that income out of AGI.

For savers considering converting traditional IRA assets to Roth IRAs, the 3.8% surtax, can be a factor in favor of conversion. Tax-free payouts from Roth IRAs don’t raise AGI or the 3.8% surtax, and there are not required payouts for the account owner. The conversion also helps reduce required payouts from traditional IRAs.

Investors should also evaluate tax-free municipal bonds or muni-bond funds, as their income is exempt from the surtax.

With higher yields, there’s more benefit to holding fixed-income assets in tax-deferred retirement accounts as opposed to taxable accounts. Actively managed mutual funds often belong in tax-deferred accounts as well.

Consider harvesting losses to offset taxable capital gains on sales of profitable assets, including the sale of a home with gains above the $250,000/$500,000 exemption. Losses can also offset tax on $3,000 of ordinary income such as wages a year, and unused losses carry forward for future use.

PLEASE VISIT OUR WEBSITE AT LSPPC.COM.

The Alabama State Bar requires the following disclosure: No representation is made that the quality of legal services to be performed is greater than the quality of legal services performed by other lawyers.

IRS Circular 230 Disclosure: To the extent this message contains tax advice, the U.S. Treasury Department requires me to inform you that any such advice, whether in the body of the message or in any attachment, is not intended or written by my firm to be used, and cannot be used by any taxpayer, for the purpose of avoiding any penalties that may be imposed under the Internal Revenue Code. Advice from my firm relating to tax matters may not be used in promoting, marketing or recommending any entity, investment plan or arrangement to any taxpayer.

Copyright © 2023 Leitman, Siegal & Payne, P.C. All rights reserved.

08/15/2023

FINANCIAL STRATEGIES FOR YOUR LIVES AND BUSINESSES
By Jackson M. Payne

TRUSTS WITH POWERS OF APPOINTMENT LIMITED BY HEMS STANDARD

In this newsletter we discuss trusts under which beneficiaries/trustees have powers limited by a so-called HEMS (health, education, maintenance, support) standard.

It's difficult, if not impossible, to draft a trust with much specificity for an environment 100 years or more in the future. A trust that may last until the 22nd century should incorporate great flexibility, in light of the unpredictability of the tax system, social conditions, etc. in the future. But this flexibility must be provided for without running afoul of the estate tax inclusion rules as they exist today-in particular, the rules governing "powers of appointment."

The donor of a power of appointment authorizes the donee to dispose of property on the donor's behalf. When the donee of the power of appointment dies, the question arises whether the property subject to the power is includible in the donee's estate for estate tax purposes. This depends primarily upon the scope of the power. Ordinarily, only a general power of appointment will cause inclusion in the donee's estate.

One tax-effective way to incorporate flexibility into a trust arrangement is to include a provision in the trust instrument that permits a trust beneficiary to be appointed as a trustee of the trust, with the ability to make discretionary distributions to himself or herself for health, education, maintenance, and support. The Code excludes from the term "general power of appointment" a power to consume, invade, or appropriate trust income or principal, or both, for the benefit of the donee of the power if it is limited by an ascertainable standard relating to his or her health, education, maintenance, or support. A standard relating to health, education, maintenance, or support is often referred to as a "HEMS standard."

According to the regs, a power is limited by an ascertainable standard if the extent of the donee's duty to exercise and not to exercise the power is reasonably measurable in terms of the donee's needs for health, education, or support, or any combination of them. But "support" as used here is not limited to the bare necessities of life. The words "support" and "maintenance" are synonymous. Whether the donee is required first to exhaust his or her other sources of revenue is of no significance in determining whether a power is limited by an ascertainable standard.

The regs give examples of ascertainable standards. Thus, there is an ascertainable standard where powers are exercisable for the donee's:

. . . support
. . . support in reasonable comfort
. . . maintenance in health and reasonable comfort
. . . support in his or her accustomed manner of living
. . . education, including college and professional education
. . . health
. . . medical, dental, hospital and nursing expenses and expenses of invalidism.

But the regs state that powers to use property for the donee's comfort, welfare, or happiness are not limited by the requisite standard.

To avoid any dispute with IRS as to whether a beneficiary/trustee has a general power of appointment, it's best if the trust instrument closely tracks the language blessed by the Code and regs.

PLEASE VISIT OUR WEBSITE AT LSPPC.COM.

The Alabama State Bar requires the following disclosure: No representation is made that the quality of legal services to be performed is greater than the quality of legal services performed by other lawyers.

IRS Circular 230 Disclosure: To the extent this message contains tax advice, the U.S. Treasury Department requires me to inform you that any such advice, whether in the body of the message or in any attachment, is not intended or written by my firm to be used, and cannot be used by any taxpayer, for the purpose of avoiding any penalties that may be imposed under the Internal Revenue Code. Advice from my firm relating to tax matters may not be used in promoting, marketing or recommending any entity, investment plan or arrangement to any taxpayer.

Copyright © 2023 Leitman, Siegal & Payne, P.C. All rights reserved.

07/18/2023

FINANCIAL STRATEGIES FOR YOUR LIVES AND BUSINESSES
By Jackson M. Payne

DISTINGUISHING BETWEEN LEGITIMATE AND SHAM TRUSTS

In this newsletter, we alert you to the availability of legitimate trusts for tax and estate planning and to steer you away from the use of trusts identified by the IRS as sham trusts, i.e., trusts that don't produce claimed tax benefits and can trigger interest and penalties.

Legitimate trusts that may properly be used to accomplish specific tax and estate planning objectives include:

(a) Marital deduction trusts that can be used to transfer amounts to your spouse without paying gift or estate tax while ensuring that the trust assets will be available for children on the spouse's death;

(b) Grantor retained annuity trusts (GRATs), grantor retained unitrusts (GRUTs) and qualified personal residence trusts (QPRTs), any of which can be set up during life to lower gift and estate tax costs of transferring property to your children;

(c) Charitable remainder annuity trusts (CRATs), charitable remainder unitrusts (CRUTs) and pooled income funds that will yield income, gift and estate tax charitable deductions and that can benefit you and your family members;

(d) Special types of trusts that you can use to you can use to make gifts to your children of amounts that would qualify for the gift tax annual exclusion and yet minimize the risk that your children will squander the funds;

(e) Life insurance trusts that can be used to keep life insurance proceeds that are subject to federal estate tax from being taxed in the insured's estate;

(f) Trusts to make gifts of S corporation stock to your minor children to save income and estate taxes while maintaining trustee control and management of the S stock;

(g) Revocable trusts that provide a benefit in having property pass to beneficiaries on the death of the owner without having to go through the probate process; and

(h) Most importantly, the spousal lifetime access trust that is used for the spouse’s lifetime benefit while taking advantage of the high estate and gift tax exemption (currently $12,920,000) before that exemption is rolled back on January 1, 2026.

On the other hand, in considering your trust options, you should know that the IRS has identified a number of sham trusts including (1) so-called business trusts, (2) equipment or service trusts, (3) family residence trusts, (4) certain purported charitable trusts, and (5) certain trusts located in foreign countries.

The so-called business trust arrangement makes it appear that an individual has given up control of his or her business in an attempt to secure a reduction in income and self-employment taxes and an elimination of estate tax on the business owner's death. This arrangement does not provide the claimed tax relief.

The equipment trust is formed to hold equipment that is rented or leased to the business trust, often at inflated rates, and the service trust is formed to provide services to the business trust, often for inflated fees. These trusts seek to reduce income taxes in different ways but the IRS warns that they do not work.

With a family residence trust, an individual transfers the family residence, including furnishings, to a trust, which rents it back to the individual. The trust deducts depreciation and the expense of maintaining and operating the residence including, pool service and utilities. These expenses are not deductible and the IRS will not allow them.

The purported charitable trust involves a transfer of assets or income to a trust claiming to be a charitable organization. The trust or organization pays for personal, educational, and recreational expenses on behalf of the transferor or one of his or her family members. The trust then claims the payments as charitable deductions on its tax return. The IRS says that many of these organizations are not exempt from tax and contributions to these trusts are not deductible.

Some individuals say that tax can be avoided by using trusts located in foreign countries that impose little or no tax on trusts and provide financial secrecy. Abusive arrangements enable taxable funds to flow through several trusts or entities until the funds are ultimately distributed or made available to the original owner. The trust promoter claims that this distribution is tax-free. But the IRS says that the income from these arrangements is fully taxable.

Needless to say, you should avoid doing business with promoters of these sham trust schemes. On the other hand, the legitimate trusts can accomplish a particular tax or estate planning objective for you and your family.

PLEASE VISIT OUR WEBSITE AT LSPPC.COM.

The Alabama State Bar requires the following disclosure: No representation is made that the quality of legal services to be performed is greater than the quality of legal services performed by other lawyers.

IRS Circular 230 Disclosure: To the extent this message contains tax advice, the U.S. Treasury Department requires me to inform you that any such advice, whether in the body of the message or in any attachment, is not intended or written by my firm to be used, and cannot be used by any taxpayer, for the purpose of avoiding any penalties that may be imposed under the Internal Revenue Code. Advice from my firm relating to tax matters may not be used in promoting, marketing or recommending any entity, investment plan or arrangement to any taxpayer.

Copyright © 2023 Leitman Siegal & Payne, P.C. All rights reserved.

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