A beneficiary did not hold general powers of appointment.
In Private Letter Ruling 200832015 (issued March 26, 2008), a trust was created for the benefit of the taxpayer. The trust was grandfathered from generation-skipping transfer tax. The taxpayer was granted a testamentary power of appointment in favor of “members of the family,” who were defined to include the grantor's children and their descendants. The taxpayer, a grandchild of the grantor, requested a ruling that the power of