Estate of Milada S. Neumann, Deceased, Eric W. Shaw, Ancillary Administrator, C.T.A. - Page 11

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            concedes that the transfers involved herein were "direct skips"                            
            and, as we have previously pointed out, does not question                                  
            respondent's calculation of the GST tax on those transfers.                                
                  In light of our holding, we have no need to explore                                  
            petitioner's arguments regarding retroactivity or the alleged                              
            failure of the Secretary to comply with the Administrative                                 
            Procedure Act, 5 U.S.C. secs. 551-559 (1988), in issuing the                               
            proposed regulations.                                                                      
                  To reflect the foregoing, and in order to take into account                          
            the settlement of certain unrelated issues,                                                
                                                             Decision will be entered                  
                                                      under Rule 155.                                  
















            3(...continued)                                                                            
            Taxes 67 (1996), analyzing the extent to which the final                                   
            regulations removed some of the gaps, etc. in the proposed                                 
            regulations.                                                                               




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