Document Type


Publication Title

Journal of Taxation

Publication Date



The Technical and Miscellaneous Revenue Act of 1988 (TAMRA) makes significant changes to Section 2036(c). Although part of the legislative history to RA '87 indicated that the section was aimed at certain limited transactions involving closely held businesses, statements in the Conference Report and subsequent developments signal that the scope and impact of Section 2036(c) may be far-reaching. Although TAMRA provides some guidance in this respect, it leaves so many areas open that it continues to be difficult to state with assurance how and when the section is intended to apply.