26 U.S. Code § 2624 - Valuation
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(a) General rule
Except as otherwise provided in this chapter, property shall be valued as of the time of the generation-skipping transfer.
(b) Alternate valuation and special use valuation elections apply to certain direct skips
(c) Alternate valuation election permitted in the case of taxable terminations occurring at death
If 1 or more taxable terminations with respect to the same trust occur at the same time as and as a result of the death of an individual, an election may be made to value all of the property included in such terminations in accordance with section 2032.
Source(Added Pub. L. 99–514, title XIV, § 1431(a),Oct. 22, 1986, 100 Stat. 2721.)