This report is submitted to the Council of the Section of Taxation, American Bar Association as a proposed response to the request of the Treasury Department for suggestions for reform of the Federal transfer taxes (the estate, gift, and generation-skipping transfer taxes). That request was contained in a letter dated November 19, 1985, from Ronald A. Pearlman, the Assistant Secretary (Tax Policy), to Hugh Calkins, then Section Chair.' After receiving individual comment papers on the subject from members of the Section's Committee on Estate and Gift Taxes, Mr. Calkins, on April 14, 1986, created this Task Force and asked it to prepare a more fundamental response.

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