Internal Revenue Service, Treasury § 25.2704–1Internal Revenue Service Agreement • December 18th, 2014
Contract Type FiledDecember 18th, 2014the 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.