(case involves estate of J. Howard Marshall, II who was married for the last 14 months of his life to Anna Nicole Smith (Vicki Lynn Marshall); J. Howard had been married to Eleanor Stevens from 1931-1961 and, as part of divorce proceedings, certain shares of stock were transferred to three CRATs and a GRIT with Stevens named income beneficiary of the GRIT; J. Howard later sold the stock back to the corporation at a value less than market value; sale constituted gift to other shareholder and GRIT; GRIT had terminated after 10 years with property passing to E. Pierce Marshall; J. Howard died shortly after sale of stock at less than market value; because GRIT had terminated, trust not in existence to pay resulting gift tax assessed against shareholders; issue involved liability for gift tax; court determined that income beneficiary rather than remainder responsible for payment of tax because income beneficiary treated as donor and benefited from increase in income distributions from trust; at time of gift donor (J. Howard's estate) was not going to pay gift tax, so gift tax liability of trust corpus).