Amended 1983
- 1983 Pub. L. 97-448 Pub. L. 97–448, § 104(a)(3)(B), amended directory language of Pub. L. 97–34, § 403(d)(3)(B)(i), to clarify that this section be inserted at end of subchapter B of chapter 12, rather than at end of subchapter B of chapter 11, and did not involve any change in text.
Cases: Estate of Anenberg v. Commissioner (T.C. 2024); Estate of Kite v. Commissioner, T.C. Memo. 2013-43
Final rules 2
(a) General rule For purposes of this chapter and chapter 11, any disposition of all or part of a qualifying income interest for life in any property to which this section applies shall be treated as a transfer of all interests in such property other than the qualifying income interest.
Amended 1983
- 1983 Pub. L. 97-448 Pub. L. 97–448, § 104(a)(3)(A), substituted “For purposes of this chapter and chapter 11, any disposition” for “Any disposition” and “treated as a transfer of all interests in such property other than the qualifying income interest” for “treated as a transfer of such property”.
(b) Property to which this subsection applies This section applies to any property if a deduction was allowed with respect to the transfer of such property to the donor—
(1) under section 2056 by reason of subsection (b)(7) thereof, or
(2) under section 2523 by reason of subsection (f) thereof.
(c) Cross reference For right of recovery for gift tax in the case of property treated as transferred under this section, see section 2207A(b).
Amended 1983
- 1983 Pub. L. 97-448 Pub. L. 97–448, § 104(a)(7), added subsec. (c).