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Gerzog on Gerson: Plain Meaning and the GSTT

Gerzog_5Ssrn_162Wendy C. Gerzog (Baltimore) has posted Gerson: Plain Meaning and the GSTT, 114 Tax Notes 701 (Feb. 12, 2007), on SSRN.  Here is the abstract:

In Gerson, the Tax Court upheld the government’s regulation regarding the grandfather exception to the generation-skipping transfer tax and held that the decedent’s exercise of a general testamentary power of appointment in 2000, granted under a trust created by her husband at his death in 1973, was subject to the GSTT. The article reviews the decision and the plain meaning of the grandfather exception to the GSTT.


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