The repeal of I.R.C. § 2036(c) in 1990 as part of the Revenue Reconciliation Act of 1990 was accompanied by enactment of rules shifting estate freezes away from federal estate tax and toward the federal gift tax arena. Proposed regulations have now been issued for the statute, I.R.C. § 2701-2704.
Harl, Neil E.
"Proposed Regulations Issued for Estate "Freezes","
Agricultural Law Digest: Vol. 2
, Article 2.
Available at: http://lib.dr.iastate.edu/aglawdigest/vol2/iss10/2