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ESTATE OF NEUMANN v. COMMISSIONER

Docket No. 11060-94.

106 T.C. 216 (1996)

ESTATE OF MILADA S. NEUMANN, DECEASED, ERIC W. SHAW, ANCILLARY ADMINISTRATOR, C.T.A., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 9, 1996.

Attorney(s) appearing for the Case

Edward L. Peck and Thomas V. Glynn, for petitioner.

Moira L. Sullivan, for respondent.

OPINION

TANNENWALD, Judge:

Respondent determined a deficiency in petitioner's Federal estate tax and generation-skipping transfer (GST) tax in the amount of $2,002,102.05. After concessions, the sole issue remaining for decision is whether the GST tax, under sections 2601 through 2663,1 applies to the transfer of U.S. situs property to decedent's grandchildren, where, at the time...

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