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<h1>Capital gain treatment for gifts: donor not taxed; recipient's later gain uses prior owner's cost and holding period.</h1> Section 47 treats transfers by gift and by will as non transfers for capital gains: the transferor does not incur capital gain, while a subsequent disposal by the recipient gives rise to capital gain computed using the previous owner's cost of acquisition and holding period. Separate provisions address the taxability of gifts in the hands of the recipient.