When an instrument creates a power of appointment, the life estate or estate for years, to which such power is subject, is immediately appraised and taxed according to the provisions of 18:26-8.2 2; however, the appraisal and taxation of the remainder interest is suspended until the exercise of the power, at which time it is taxed at the clear market value as of date of death of the death of the creator of the power.
N.J. Admin. Code § 18:26-8.24