[Code of Federal Regulations]
[Title 26, Volume 14]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR25.2523(h)-1]

[Page 622]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 25_GIFT TAX; GIFTS MADE AFTER DECEMBER 31, 1954--Table of Contents
 
Sec.  25.2523(h)-1  Denial of double deduction.

    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.

[T.D. 8522, 59 FR 9663, Mar. 1, 1994]