Code of Federal Regulations · Section
§ 25.2523(h)-1 — (h)-1 Denial Of Double Deduction
26 C.F.R. § 25.2523(h)-1
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The value of an interest in property may not be deducted for Federal gift tax purposes more than once with respect to the same donor. For example, assume that D, a donor, transferred a life estate in a farm to D's spouse, S, with a remainder to charity and that D elects to treat the property as qualified terminable interest property. The entire value of the property is deductible under section 2523(f). No part of the value of the property qualifies for a charitable deduction under section 2522 for gift tax purposes.
Authorizing Statute
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Extension of time for filing returns26 U.S.C. § 6081
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Unified credit against estate tax26 U.S.C. § 2010
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Mode or time of collection26 U.S.C. § 6302
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Rules and regulations26 U.S.C. § 7805
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Information returns of tax return preparers26 U.S.C. § 6060
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Valuation tables26 U.S.C. § 7520
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Disclaimers26 U.S.C. § 2518
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Identifying numbers26 U.S.C. § 6109