In re the Estate of Tubbs

Larson, J.:

Bert B. Lewis III and Tonya Lewis May, the residuary takers under the will of Esther Tubbs, appeal the total deple*397tion of the estate’s residuary by fhe payment therefrom of fhe Generation Skipping Transfer Tax (GSTT) imposed by the Internal Revenue Code § 2601 et seq. (1988).

The residuary takers contend: (1) The GSTT should have been paid by and charged against the transfers generating the tax, (2) the executor’s allocation of the statutory $1 million GSTT exemption exclusively to transfers other than the residuary estate was improper, (3) fhe trial court erred in failing to…