- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011