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  3. 2.) should section 2512(b) be viewed as a part of

2.) Should Section 2512(b) be viewed as a part of the definition of "gift" or...

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Accounting

2.) Should Section 2512(b) be viewed as a part of the definition of "gift" or as a measuring rod for transfers otherwise identified as gifts? For example, for several months C negotiated with a parent's sibling T for the purchase of 100 acres of T's ranch. T finally sells the property to C for $1,900,000. If the Commissioner asserts, and it cannot be disproved, that the property was worth $2,000,000:

a.) Has T made a gift? See Reg. 25.2512-8.

b.) Is T's intent, donative or otherwise, entirely irrelevant?

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