26 U.S.C. § 2623
For purposes of this chapter, the taxable amount in the case of a direct skip shall be the value of the property received by the transferee.
(Added Pub. L. 99–514, title XIV, § 1431(a), , 100 Stat. 2721.)
Section applicable to generation-skipping transfers (within the meaning of section 2611 of this title) made after , except as otherwise provided, see section 1433 of Pub. L. 99–514, set out as a note under section 2601 of this title.