One portion is equal to the amount of the nontaxable transfer ($10,000) and has a zero inclusion ratio; the other portion is $2,000 ($12,000 â $10,000). With respect to the $2,000 portion, the denominator of the applicable fraction is $2,000. made no prior gifts to or for the benefit of GC during 1996. The entire $10,000 transfer is a nontaxable transfer. For purposes of computing the tax on the direct skip, the denominator of the applicable fraction is zero, and thus, the inclusion ratio is zero.
prole f (plural proli) 1  offspring, issue, children quotations â¼ senza prole - childless. 2  progeny, race, stock.
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