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39. To clarify, it doesn't promote Grant to a 5-star general. It authorizes the President to promote

one rank higher, specific General of the Armies. The NDAA does address the number of stars.

The five-star General of the Army rank (and it's navy equivalent of Fleet Admiral) were WWII creations designed to provide equivalency with other nations' positions such as Field Marshal. Only Omar Bradley was promoted to General of the Army after WWII.

When General of the Army was established, General of the Armies John J. Pershing was still alive and the administration wanted it to be clear that the newly-created five-star rank would remain junior to Pershing - who never wore more than 4 stars. On at least one occasion, Pershing did wear 4 gold stars and this provided a difference from a General's 4 silver stars.

the NDAA permits promotion of Grant to the higher rank. If the President exercises the authority to promote Grant, he would join Pershing and Washington as the third officer holding the rank.