Estate of Charles K. McClatchy, Deceased, William K. Coblentz and James McClatchy, Personal Representative - Page 15

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               Petitioner also argues that the general policy of the                  
          unified gift and estate transfer tax system (enacted as a part of           
          The Tax Reform Act of 1976, Pub. L. 94-455, sec. 2001, 90 Stat.             
          1520, 1846) dictates that the restrictions have an effect on the            
          determination of value for estate tax purposes, and that since              
          the securities law restrictions were applicable to gifts by the             
          decedent, they are required to be taken into account in this case           
          for the sake of consistency.  Petitioner's argument is not                  
          convincing.                                                                 
               According to a Joint Committee "Blue Book", Congress                   
          believed that, as a matter of equity, transfers of the same                 
          amount of wealth should be treated substantially the same when              
          transfers were made both during life and at death, or made only             
          upon death.  Congress believed that it was desirable to reduce              
          the disparity of treatment between lifetime transfers and                   
          transfers at death through the adoption of a single unified                 
          estate and gift tax rate schedule providing progressive rates               
          based on cumulative transfers.  See Staff of Joint Committee on             
          Taxation, General Explanation of the Tax Reform Act of 1976 (J.             
          Comm. Print), 1976-3 C.B. (Vol. 2) 537.  Accordingly, the Tax               
          Reform Act of 1976 provided a rate schedule for estate and gift             
          taxes which eliminated the preferential rate for lifetime                   
          transfers.  The Tax Reform Act of 1976 also provided for a                  
          unified credit against estate and gift taxes.  The amount of the            





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