[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: 26CFR25.2703-2]

[Page 670]
 
                       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.  25.2703-2  Effective date.

    Section 25.2703-1 applies to any right or restriction created or 
substantially modified after October 8, 1990, and is effective as of 
January 28, 1992. With respect to transfers occurring prior to January 
28, 1992, and for purposes of determining whether an event occurring 
prior to January 28, 1992 constitutes a substantial modification, 
taxpayers may rely on any reasonable interpretation of the statutory 
provisions. For these purposes, the provisions of the proposed 
regulations and the final regulations are considered a reasonable 
interpretation of the statutory provisions.

[T.D. 8395, 57 FR 4274, Feb. 4, 1992]