2651(e) broadens the
predeceased parent rule by expanding its application to transfers (1) that would be taxable distributions or taxable terminations and (2) to collateral heirs, provided that the transferor has no living lineal descendants at the time of transfer.
The proposed regulations implement statutory changes that expanded the application of the
predeceased parent rule to additional transfers and recipients.
The decedent also held interests in the same partnership via a QTIP trust for her benefit under the will of her
predeceased spouse; such interests were includible in her estate under Sec.
301.9100-1), expansions of the
predeceased parent exception, and allowing taxpayers to pay the tax when discovered and stop the GSTT consequences going forward from that date.
Of course, without the
predeceased child rule, both trusts would have been subject to GST tax.
Besides her husbands, she was
predeceased by her son, James Raymond in 1984, her daughter, Cheryl Carson, in 1986 and her brother, Richard Huard, of Paxton.
In contrast, the primary beneficiaries of the trust in Cristofani were the taxpayer's children; the taxpayer's grandchildren held only contingent remainder interests in the trust, which vested only in the event that their parents
predeceased the taxpayer or failed to survive her by more than 120 days.
Gerald
predeceased her in 1999; their daughter, Joanne Coleman,
predeceased them in 1996; and their daughter, Wendy Frazier,
predeceased her in May 2013.Gloria is survived by her son-in-law, Dennis Frazier of Holden; four loving grandchildren, Jacquelyn Frazier and Victoria Frazier both of Holden, Joseph Saliba of Boston and Thomas Saliba of Worcester; a great grandson, Leon; and many nieces and nephews.
Her sister, Lorraine (Brown) Chartier, wife of Eugene Chartier,
predeceased her.
She was
predeceased by her son, Allan John Estey, III.