26 C.F.R. § 25.2523(h)-1 Denial of double deduction.
Title 26 - Internal Revenue
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]
Title 26: Internal Revenue
PART 25—GIFT TAX; GIFTS MADE AFTER DECEMBER 31, 1954
Deductions
§ 25.2523(h)-1 Denial of double deduction.
