The separate share rule of Code § 663(c) requires that separate and independent shares of different beneficiaries in the same estate or trust be treated as separate shares or trusts in determining the distributable net income (DNI) allocable to the respective beneficiaries. Before the Taxpayer Relief Act of 1997, P.L. 105-34, the separate share rule applied only to trusts and not to estates and received little attention from practitioners.

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