In Re Estate of Denman

OPINION

Opinion by: STEVEN C. HILBIG, Justice.

This is an appeal from the probate court’s judgment construing section 2603(b) of the Internal Revenue Code and provisions in the will of Gilbert M. Den-man, Jr. (“the Will”) to determine the proper allocation of the federal generation-skipping transfer tax (“GST tax”). Appellants Leroy G. Denman, Jr., as independent coexecutor (“Denman”), and Wendel Denman Thuss, a beneficiary under the Will (“Thuss”), urged the tax should be charged and allocated to the residuary estate. Appellees The Trust Company, a coexecutor of the Will and co-trustee of a…