Edward L. Peck and Thomas V. Glynn, for petitioner. Moira L. Sullivan, for respondent. OPINION TANNENWALD, Judge: Respondent determined a deficiency in petitioner's Federal estate tax and generation-skipping transfer (GST) tax in the amount of $2,002,102.05. After concessions, the sole issue remaining for decision is whether the GST tax, under sections 2601 through 2663,1 applies to the transfer of U.S. situs property to decedent's grandchildren, where, at the time of death, decedent was a nonresident alien and regulations had not yet been promulgated under section 2663(2). All the facts have been stipulated and are so found. The stipulation of facts and the exhibits attached thereto are incorporated herein by this reference. Petitioner is the estate of Milada S. Neumann (decedent) who died testate on July 14, 1990. Decedent was a resident and citizen of the Republic of Venezuela at the time of her death. Eric W. Shaw is the ancillary administrator and resided in Larchmont, New York, at the time the petition was filed. Decedent's will was admitted to ancillary probate by the Surrogate's Court of New York County, New York. As translated into English, the will provides in part as follows: 1 All statutory references are to the Internal Revenue Code in effect as of the date of decedent's death, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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