United States Sixth Circuit

District court's decision that transfers from an Estate trust do not fall within the statutory grandfathering exemption to the generation-skipping transfer tax is affirmed as the grandfathering exemption is ambiguous as applied to this case, the regulation at issue is a reasonable interpretation of the statute, and the transfer at issue falls within that regulation.

Appellate Information

• Decided 04/02/2010
• Published 04/02/2010

Judges

Court

• United States Sixth Circuit

Counsel