§2601 — Tax imposed

16 cases·3 overruled·13 cited

Statute Text — 26 U.S.C. §2601

A tax is hereby imposed on every generation-skipping transfer (within the meaning of subchapter B).

Treasury Regulations

Treas. Reg. §Treas. Reg. §26.2601-1 Effective dates
Treas. Reg. §Treas. Reg. §26.2601-1(a) Transfers subject to the generation-skipping transfer tax—(1) In general.
Treas. Reg. §Treas. Reg. §26.2601-1(b) Exceptions—(1) Irrevocable trusts—(i) In general.
Treas. Reg. §Treas. Reg. §26.2601-1(c) Additional effective dates.
Treas. Reg. §Treas. Reg. §26.2601-1(i) §26.2601-1(i)
Treas. Reg. §Treas. Reg. §26.2601-1(v) Rule applies even if another person has power to change trust terms.

16 Citing Cases

Estate of Jane H. Gudie, Deceased, Mary Helen Norberg, Executor, Petitioners 137 T.C. No. 13 · 2011

to file amendment to answer, filed December 23, 2010, was granted. In the motion respondent alleged that the gifts made in 1992 were made to "skip persons" under section 2613 and accordingly were subject to the generation-skipping transfef tax under section 2601. The motion asserted an increased deficiency in estate tax of $4,972,876.30 . lAll section references are to the Internal Revenue Code of 1986, as amended and in effect for the date of decedent's death. All Rule references are to the Tax

Estate of Gudie v. Commissioner 137 T.C. 165 · 2011

to file amendment to answer, filed December 23, 2010, was granted. In the motion respondent alleged that the gifts made in 1992 were made to “skip persons” under section 2613 and accordingly were subject to the generation-skipping transfer tax under section 2601. The motion asserted an increased deficiency in estate tax of $4,972,876.30 and an increased section 6662(a) accuracy-related penalty of $994,575.26. On June 9, 2011, Ms. Norberg filed a motion to dismiss. On June 17, 2011, respondent wa

E. Norman Peterson Marital Trust; Chemical Bank, Trustee, Petitioners 102 T.C. No. 38 · 1994

Discussion Section 2601 imposes the GST tax on every generation- skipping transfer.

E. Norman Peterson Marital Trust v. Commissioner 102 T.C. 790 · 1994

Discussion Section 2601 imposes the GST tax on every generation-skipping transfer.

Conoshenti v. Pub Ser Elec & Gas · Cir.

Rodney Harrell v. Freedom Mortgage Corporation 976 F.3d 434 · Cir.

Richard Conoshenti v. Public Service Electric & Gas Company 364 F.3d 135 · Cir.

O'Neal v. Commissioner 102 T.C. 666 · 1994

Reed v. Commissioner 90 T.C. 698 · 1988

Porter v. Commissioner 88 T.C. 548 · 1987

Estate of Richardson v. Commissioner 89 T.C. 1193 · 1987

Ellis v. Commissioner 51 T.C. 182 · 1968

Estate of Timken v. United States 601 F.3d 431 · Cir.

Eastman v. Marine Mechanical · Cir.

United States v. Frederick Schultz 333 F.3d 393 · Cir.

John T. Eastman v. Marine Mechanical Corporation 438 F.3d 544 · Cir.