Tax Notes (a publication of Tax Analysts)
Jonathan G. Blattmachr, Diana S. C. Zeydel, and Mitchell M. Gans examine section 2523(b)(2)'s history and conclude that it was intended to deal with the limited situation in which the power of appointment created by the donor spouse has been conferred on the donor spouse by a third party.
Jonathan G. Blattmachr, Diana S.C. Zeydel, and Mitchell M. Gans,
The World's Greatest Gift Tax Mystery, Solved, 115 Tax Notes 243
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