§2622 — Taxable amount in case of taxable termination

4 cases·2 distinguished·1 overruled·1 cited

Statute Text — 26 U.S.C. §2622

(a)In general

For purposes of this chapter, the taxable amount in the case of a taxable termination shall be—

(1)

the value of all property with respect to which the taxable termination has occurred, reduced by

(2)

any deduction allowed under subsection (b).

(b)Deduction for certain expenses

For purposes of subsection (a), there shall be allowed a deduction similar to the deduction allowed by section 2053 (relating to expenses, indebtedness, and taxes) for amounts attributable to the property with respect to which the taxable termination has occurred.

4 Citing Cases

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

Unlike a direct skip, however, the transferee of a taxable distribution (rather than the trustee) is liable for payment of the GST tax and the related expenses. Sec. 2603(a)(1). Because the amount received by the transferee includes the property that will be used by the transferee to pay administrative expenses, sec. 2621(a)(2) explicitly allows a reduction in the taxable amount for these expenses As with a direct skip, the trustee is liable for payment of the GST tax in the case of a taxable te

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

In the case of direct skips, such as the transfers at issue, the taxable amount is “the value of the property received by the transferee.” Sec. 2623. Respondent argues that these statutory provisions require that no deduction be allowed for interest expenses in the context of a direct skip. Respondent emphasizes that the definitions of t

Gary Vander Boegh v. EnergySolutions, Inc. 772 F.3d 1056 · Cir.

Willy v. Administrative Review Board 423 F.3d 483 · Cir.

§2622 — Taxable amount in case of taxable termination

4 Citing Cases

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