21 years of age whether or not he resides in the transferor's household, provided that such expenditure does not result in such person or child acquiring property which will retain significant value after the passage of one year from the date of such expenditure; or (b) current educational, medical or dental costs of any person; or (c) current costs of food, clothing and maintenance of living accommodations of any person in fact dependent on the transferor, in whole or in part, for support, provided such expenditure is reasonable in amount. 8. The 100% charitable deduction in the field of transfer taxation should be retained, under either a dual tax system or a unified tax. 9. A charitable deduction should be allowed on a waitand-see basis, with respect to charitable gifts of uncertain value, under either a dual tax system or a unified tax. 10. The fixed dollar amount deduction approach for the benefit of a recipient of previously-taxed property should be adopted, under either a dual tax system or a unified tax. 11. The previously-taxed-property provision should apply to a transfer by death followed by the death of the recipient, under either a dual tax system or a unified tax, but should apply to a lifetime transfer followed by the death of the recipient only under a unified tax. 12. The previously-taxed-property benefit to the recipient should be available on a 100% basis for the first six years and should diminish by 20% each year thereafter and terminate completely after ten years, under either a dual tax system or a unified tax. 13. Under either a dual tax system or a unified tax, an additional tax should be imposed to deal with the problem of the avoidance of transfer taxes by a succession of limited beneficial interests that may continue through several generations. 14. Under either a dual tax system or a unified tax, an additional tax should not be imposed on an outright transfer, or its equivalent. 15. Under either a dual tax system or a unified tax, the additional tax should be applicable to the transfer of a limited interest if, but only if, distribution of benefits may be made under the transfer to a person more than one generation below the transferor at a time subsequent to the death of a person one generation below the transferor. Such additional tax should be: (a) imposed at the average rate applicable to all transfers by the transferor in the taxable period of the transfer, (b) imposed at the time of the transfer or at the time of distribution to a person more than one generation below the transferor, as the transferor or his personal representative may elect, and (c) collectible only out of the property on which the additional tax is imposed, unless the transfer or specifies other funds out of which the additional tax is to be paid. 16. The 100% marital deduction should be adopted in place of the 50% marital deduction, under either a dual tax system or a unified tax. 17. The terminable-interest rule in relation to marital deduction transfers should be abolished and a current-beneficial-enjoyment test adopted, under either a dual tax system or a unified tax. 18. Under either a dual tax system or a unified tax, an election should be available to have qualified marital deduction transfers taxed in whole or in part as though they did not qualify for the marital deduction, and to the extent such an election is made, no transfer tax should be imposed on identifiable previously-taxed property when beneficial enjoyment passes from the donee spouse to others. 19. Gift splitting by husband and wife should be allowed on a transfer by either one to others in connection with deathtime transfers as well as lifetime transfers, under either a dual tax system or a unified tax. 20. If the 100% marital deduction is adopted, gift split donor spouse, under either a dual tax system or a unified tax. 21. The Internal Revenue Code, under either a dual tax system or a unified tax, should define what constitutes a disclaimer. 22. Timely redirection of the destination of a property interest should be regarded as a disclaimer for the purpose of determining the transfer tax consequences of the original transfer, under either a dual tax system or a unified tax. 23. A line between completed and uncompleted gifts should be definitively established, so that all lifetime arrangements would fall on one side of the line or the other, and so that there would be no area where the same transfer is subject to transfer taxation both as a lifetime transfer and a deathtime transfer, under either a dual tax system or a unified tax. 24. Under a unified tax, an easy-to-complete-gift rule should be adopted in the power cases which would eliminate the significance of a power in a lifetime arrangement to prevent a completed gift unless (a) the power can be exercised in favor of the transferor, and (b) the power is exercisable by the transferor alone or in conjunction with one who does not have a substantial interest that would be adversely affected by the exercise of the power. 25. Under a dual tax system, a hard-to-complete-gift rule should be adopted in the power cases which would prevent a lifetime arrangement from being a completed gift if there is a power in anyone to modify who takes or to modify when a beneficiary takes, except that an otherwise completed gift would not be incomplete if the power is in one or more persons other than the transferor and (a) is exercisable only by will, or (b) such power-holder is treated as the owner of the transferred property for transfer tax purposes, or (c) not more than half of the power-holders are in the related or subordinate category as defined by I.R.C. Sec. 672. 26. A transfer with current beneficial enjoyment retained by the transferor should be considered an incomplete gift as long as the transferor retains the current beneficial enjoyment, under either a dual tax system or a unified tax. 27. The value of a reversionary interest retained by the transferor that is certain to become possessory, and of all succeeding interests, should be considered an incomplete gift as long as such retained interest is held by the transferor, under either a dual tax system or a unified tax. 28. A lifetime arrangement for the disposition on the death of an employee of an employee death benefit should be considered an incomplete gift, under either a dual tax system or a unified tax. 29. No completed gift with respect to life insurance should be considered to take place so long as the insured retains any incident of ownership in the policy, under either a dual tax system or a unified tax. 30. Under a dual tax system, the present law as to gifts in contemplation of death should be retained, except that when a gift is in contemplation of death, a refund should be allowed for the amount of any gift tax paid thereon, or if the gift tax thereon has not been paid the liability therefor should terminate. 31. Under a unified tax, the amount paid in transfer taxes on a lifetime transfer made in either of the two taxable periods prior to the transferor's death should be subject to transfer taxation. 32. A rate schedule, under either a dual tax system or a unified tax, that progresses slowly through the lower taxable amounts is preferable to one that progresses steeply through such amounts. 33. There should be no differential in the rate schedules for lifetime and deathtime transfers under a dual tax system, so as to keep the rates on deathtime transfers as low as possible. 34. An exemption of [$100,000] for a unified tax should be allowed in preference to a lower exemption that would permit lower rates in the other brackets in order to produce any required amount of revenue. 35. An exemption of [$30,000] for the gift tax should be retained and of [$100,000] for the estate tax should be allowed under a dual tax system, in preference to lower exemptions that would permit lower rates in the various brackets in order to produce any required amount of revenue. 36. An annual per-donee exclusion of [$3,000] for presentinterest lifetime transfers should be retained, but with an annual per-donor limit of [$15,000] if an exclusion of transfers for consumption is adopted, under either a dual tax system or a unified tax. 37. Under a continuation of the dual tax system, the lifetime exemption for lifetime transfers should be the lifetime exemption for gifts under the new law, less the amount of prior gifts properly chargeable against the lifetime exemption under the old law. 38. Under a continuation of the dual tax system, prior taxable lifetime transfers should be taken into account in locating the bracket under the new gift tax schedule that is to apply to future lifetime gifts. 39. Under a unified tax, prior transfers should be ignored entirely in regard to the exemption available and the beginning rate bracket applicable to future lifetime and deathtime transfers. 40. The effective date for unification should be some reasonable period after enactment so that there would be a period between enactment and effective date when gifts could be made under present law. 41. A 100% tax-free interspousal transfer rule, if enacted, should be effective immediately upon enactment. 42. Any new rate schedule should be effective immediately upon enactment, except that in the event of unification the old gift tax rate schedule should be in effect for inter vivos gifts until the effective date for unification. 43. In the case of any transfer prior to the enactment of the new law which was complete under the old law, no tax should be imposed under any provision of the new law until |