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ESTATE OF GERSON v. COMMISSIONER

Docket No. 13534-04.

127 T.C. 139 (2006)

127 T.C. No. 11

ESTATE OF ELEANOR R. GERSON, DECEASED, ALLAN D. KLEINMAN, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 24, 2006.

Attorney(s) appearing for the Case

Mark A. Phillips and Jeffry L. Weiler, for petitioner.

Stephen J. Neubeck, for respondent.

OPINION

HAINES, Judge:

Respondent issued a notice of deficiency to the Estate of Eleanor R. Gerson (the estate) determining a deficiency of $1,144,465 in Federal generation-skipping transfer (GST) tax. The sole issue before the Court concerns the validity of section 26.2601-1(b)(1)(i), GST Tax Regs., which provides that the "grandfather" exception to the GST tax set forth in section 1433(b)(2)(A) of the Tax Reform Act of 1986 (TRA 1986), Pub. L. 99...

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