15 pages. Excerpt:'If a marital trust described in Situations 1, 2, or 3 is the named beneficiary of a decedent's [IRA] or ... defined contribution plan, under what circumstances is the surviving spouse considered to have a qualifying income interest for life in the IRA (or qualified retirement plan) and in the trust for purposes of an election to treat both the IRA and the trust as qualified terminable interest property (QTIP) under § 2056(b)(7) of the Internal Revenue Code?