[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: 26CFR25.2704-3]

[Page 674]
 
                       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.  25.2704-3  Effective date.

    Section 25.2704-1 applies to lapses occurring after January 28, 
1992, of rights created after October 8, 1990. Section 25.2704-2 applies 
to transfers occurring after January 28, 1992, of property subject to 
applicable restrictions created after October 8, 1990. In determining 
whether a voting right or a liquidation right has lapsed prior to that 
date, and for purposes of determining whether the lapse is subject to 
section 2704(a), taxpayers may rely on any reasonable interpretation of 
the statutory provisions. For transfers of interests occurring before 
January 28, 1992, taxpayers may rely on any reasonable interpretation of 
the statutory provisions in detemining whether a restriction is an 
applicable restriction that must be disregarded in determining the value 
of the transferred interest. 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 4277, Feb. 4, 1992; T.D. 8395, 57 FR 11265, Apr. 2, 
1992]

                      Procedure and Administration