[Amount of the gift (C) / Total taxable gifts, plus specific exemption allowed (D)] * Total gift tax paid (B)
For purposes of the ratio stated in the preceding sentence, the amount of the gift referred to as factor "C" is the value of the gift reduced by any portion excluded or deducted under section 2503(b) (annual exclusion), 2522 (charitable deduction), or 2523 (marital deduction) of the Code or the corresponding provisions of prior revenue laws. In making the computations described in this paragraph, the values to be used are those finally determined for purposes of the gift tax.
Value of land given to W | $60,000 | ||
Less: Annual exclusion | $3,000 | ||
Marital deduction | 30,000 | 33,000 | |
Included amount of gift | $27,000 | ||
Value of securities given to S | 60,000 | ||
Less: Annual exclusion | 3,000 | ||
Included amount of gift | 57,000 | ||
Gift to charitable organization | 5,000 | ||
Less: Annual exclusion | 3,000 | ||
Charitable deduction | 2,000 | 5,000 | |
Included amount of gift | 0 | ||
Total included gifts | 84,000 | ||
Less: Specific exemption allowed | 30,000 | ||
Taxable gifts for 1959 | 54,000 | ||
Gift tax on $54,000 | 6,000 |
In determining the gift tax paid with respect to the land given to W, amount C of the ratio set forth in subparagraph (1)(ii) of this paragraph is $60,000, value of property given to W, less $33,000 (the sum of $3,000, the amount excluded under section 2503(b), and $30,000, the amount deducted under section 2523), or $27,000. Amount D of the ratio is $84,000 (the amount of taxable gifts, $54,000, plus the gift tax specific exemption, $30,000). The gift tax paid with respect to the land given to W is $1,928.57, computed as follows:
$27,000(C) ÷ $84,000(D) * $6,000(B)
A | B | |
Value of land given to N | $43,000 | $43,000 |
Less: exclusion | 3,000 | 3,000 |
Included amount of gift | 40,000 | 40,000 |
Value of securities given to N | 20,000 | 20,000 |
Less: exclusion | None | None |
Included amount of gift | 20,000 | 20,000 |
Cash gift to S | 23,000 | 23,000 |
Less: exclusion | 3,000 | 3,000 |
Included amount of gift | 20,000 | 20,000 |
Total included gifts | 80,000 | 80,000 |
Less: specific exemption | None | 30,000 |
Taxable gifts for 1956 | 80,000 | 50,000 |
Gift tax for 1956 | 11,325 | 5,250 |
The amount of the gift tax paid by A with respect to the land given to N is computed as follows:
$40,000(C) / $80,000(D) * $11,325(B) = $5,662.50
The amount of the gift tax paid by B with respect to the land given to N is computed as follows:
$40,000(C) / $80,000(D) * $5,250(B) = $2,625
The amount of the gift tax paid with respect to the land is $5,662.50 plus $2,625, or $8,287.50. Computed in a similar manner, the amount of gift tax paid by A with respect to the securities given to N is $2,831.25, and the amount of gift tax paid by B with respect thereto is $1,312.50, or a total of $4,143.75.
Value of real estate transferred to Y | $100,000 | |
Less: Annual exclusion | 10,000 | |
Included amount of gift (C) | $90,000 | |
Value of painting transferred to Z | $70,000 | |
Less: annual exclusion | 10,000 | |
Included amount of gift | 60,000 | |
Total included gifts (D) | $150,000 | |
Total gift tax liability for 1995 gifts (B) | $55,500 |
26 C.F.R. §1.1015-5