Estate of Timken v. United States

OPINION

ROGERS, Circuit Judge.

The Estate of Louise Blyth Timken appeals the district court’s decision on cross- motions for summary judgment that transfers from a Timken Estate trust do not fall within the statutory grandfathering exemption to the generation-skipping transfer tax (GST tax). The district court correctly held, however, that the grandfathering exemption is ambiguous as applied to this case, that the regulation at issue is a reasonable interpretation of the statute, and that the transfers at issue fall within that regulation. Therefore, the district court properly upheld the…