In re the Estate of Jacobs

OPINION OF THE COURT

Eve Preminger, S.

In connection with the judicial settlement of the final account of proceedings of the executor of the estate of William K. Jacobs, Jr., the guardian ad litem for an infant beneficiary raises a novel question as to whether an "equitable adjustment” is required as a result of the executor’s allocation of the testator’s $1,000,000 exemption from generation-skipping transfer (GST) tax imposed by chapter 13 of the Internal Revenue Code (26 USC).

The testator died on July 30, 1991, leaving a will dated May 23, 1991 by which he disposes of his approximately…