Extent of gift: if donees fail to assume exclusive possession, the gifted property's value is includible in the donor's estate. Where donees do not immediately and bona fide assume exclusive possession and enjoyment of gifted property and do not thereafter retain it to the entire exclusion of the donor or any benefit to him, the part of the property itself so not assumed shall be deemed to pass on the donor's death and its value is includible in the donor's estate; this modifies prior Board guidance that looked only to the donor's retained interest.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Extent of gift: if donees fail to assume exclusive possession, the gifted property's value is includible in the donor's estate.
Where donees do not immediately and bona fide assume exclusive possession and enjoyment of gifted property and do not thereafter retain it to the entire exclusion of the donor or any benefit to him, the part of the property itself so not assumed shall be deemed to pass on the donor's death and its value is includible in the donor's estate; this modifies prior Board guidance that looked only to the donor's retained interest.
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