§2623 — Taxable amount in case of direct skip
2 cases·1 distinguished·1 criticized
Statute Text — 26 U.S.C. §2623
For purposes of this chapter, the taxable amount in the case of a direct skip shall be the value of the property received by the transferee.
2 Citing Cases
taxes of the kind that would be allowable under section 2053 (relating to the Federal estate tax). Sec. 2622. 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 Because the GST tax on a direct skip is imposed only on the amount received and the taxable amount does not include
taxes of the kind that would be allowable under section 2053 (relating to the Federal estate tax). Sec. 2622. 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 taxable amount with respect to taxable distributions