[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: 26CFR25.2701-7] [Page 649] 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. 25.2701-7 Separate interests. The Secretary may, by regulation, revenue ruling, notice, or other document of general application, prescribe rules under which an applicable retained interest is treated as two or more separate interests for purposes of section 2701. In addition, the Commissioner may, by ruling issued to a taxpayer upon request, treat any applicable retained interest as two or more separate interests as may be necessary and appropriate to carry out the purposes of section 2701. [T.D. 8395, 57 FR 4264, Feb. 4, 1992] [[Page 650]]