(1) a gift made to a trust is to take effect at a date later than the date of the gift instrument; and
(2) when the gift instrument is executed, the gift to the trust would qualify for a charitable deduction under the Internal Revenue Code (26 U.S.C.), if the gift were then effective; and
(3) the trust, or beneficiary of the trust, loses its tax-exempt status before the gift takes effect; THEN
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