Estate of Eleanor R. Gerson, Deceased, Allan D. Kleinman, Executor - Page 26

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          at 820, 1986-3 C.B. (Vol. 2) at 820, describing then-present law,           
          under the heading “Overview”, the Committee understood the GST              
          tax was imposed on a transfer from a trust which specifically               
          provided for distributions to a generation at least two                     
          generations removed from the grantor.  This viewpoint is                    
          reiterated in H. Rept. 99-426, at 821, 1986-3 C.B. (Vol. 2) at              
          821, under the heading “Generation assignment”, which states in             
          pertinent part:  “A generation-skipping trust is a trust having             
          two or more generations of ‘beneficiaries’ who belong to                    
          generations which are ‘younger’ than the generation of the                  
          grantor of the trust.”  Significantly, nothing in the committee             
          reports suggests that, when Congress referred to “transfers under           
          a trust”, it ever contemplated or considered a volitional                   
          generation-skipping transfer arising from the exercise of a                 
          general power of appointment as opposed to a specific transfer by           
          the settlor to identified persons.                                          
          Second, in H. Rept. 99-426, supra at 824, 1986-3 C.B. (Vol.                 
          2) at 824, the Committee stated, under the heading “Reasons for             
          Change”:                                                                    
                    The committee believes, as it stated when the                     
               generation-skipping transfer tax originally was enacted                
               in 1976, that the purpose of the three transfer taxes                  
               (gift, estate, and generation-skipping) is not only to                 
               raise revenue, but also to do so in a manner that has                  
               as nearly as possible a uniform effect.  This policy is                
               best served when transfer tax consequences do not vary                 
               widely depending on whether property is transferred                    
               outright to immediately succeeding generations or is                   
               transferred in ways that skip generations. * * * The                   
               bill accomplishes the committee’s goal of simplified                   




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