In re the Estate of Spear

OPINION OF THE COURT

Renee R. Roth, S.

The issue in this proceeding is whether testator’s residuary *1047disposition, which makes a direct skip to his grandchildren, presently qualifies, or can be qualified by reformation for the $2,000,000 grandchild (Gallo) exclusion from generation-skipping transfer (GST) tax.

Testator, Nathaniel Spear, Jr., died on January 5, 1988 léaving a will dated June 22, 1987. Thus, Mr. Spear’s will was executed and his death occurred after the enactment of the Tax Reform Act of 1986 (Pub L 99-514) (TRA 1986). That statute retroactively repealed the old GST tax and enacted…