Estate of Milada S. Neumann, Eric W. Shaw, Ancillary Administrator, C.T.A. v. Commissioner

106 T.C. No. 10

UNITED STATES TAX COURT ESTATE OF MILADA S. NEUMANN, DECEASED, ERIC W. SHAW, ANCILLARY ADMINISTRATOR, C.T.A., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11060-94. Filed April 9, 1996. Decedent, a nonresident alien, died in 1990. She bequeathed U.S. situs property outright to her grandchildren. In 1986, bequests of this type, i.e., "direct skips", were first subjected to the generation- skipping transfer (GST) tax provisions of secs. 2601 through 2663, I.R.C. At the time of decedent's death, regulations dealing with "direct skips" had not been issued.…