- 15 - 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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