- 11 -
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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Last modified: May 25, 2011