T and T’s. child, C, each own 50 percent of the outstanding stock of X cor- poration. T and C enter into an agreement in 1987 providing for the disposition of stock held by the first to die at the time of death. The agreement also provides certain restric- tions with respect to lifetime transfers. In 1992, as permitted (but not required) under the agreement, T transfers one-half of T’s stock to T’s spouse, S. S becomes a party to the agreement between T and C by reason of the transfer. The transfer is the addition of a family member to the right or restriction. However, it is not a substantial modification of the right or restriction because the added family member would be assigned to a gen- eration under section 2651 of the Internal Revenue Code no lower than the generation occupied by C.
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