bm30003700[at]aol.com wrote:

- quote -

My book of final and temporary regs has 301.6501(c)-1(e)(1)

(e) Gifts subject to chapter 14 of the Internal Revenue Code
not adequately disclosed on the return.

(1) IN GENERAL.

If any transfer of property subject to the special valuation
rules of section 2701 or section 2702, or if the occurrence
of any taxable event described in section 25.2701-4 of this
chapter, is not adequately shown on a return of tax imposed
by chapter 12 of subtitle B of the Internal Revenue Code
(without regard to section 2503(b)), any tax imposed by
chapter 12 of subtitle B of the Code on the transfer or
resulting from the taxable event may be assessed, or a
proceeding in court for the collection of the appropriate
tax may be begun without assessment, at any time.

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After posting this message, I found out that the copy of
regulation I was reading erred in not putting (1) in the
paragraph preceding (2). Moral of the story; don't trust
everything you pull from the internet!

Anyway, thanks!

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"bm30003700[at]aol.com" <bm30003700[at]aol.com> wrote:

- quote -

By the way it reads, they just forgot to label the
first paragraph properly. What you are reading as
301.6501(c)-1(e) is really 301.6501(c)-1(e)(1).

Stu

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bm30003700[at]aol.com wrote:

- quote -

Depending on what source you are using to look at the
regulations, sometimes the reference to sub-subparagrah (1)
is tucked up against the reference to subparagraph (e).
It's easy to overlook. Here is the text of the two sections
you are looking at:

301.6501(c)-1(e)(1):

In general. If any transfer of property subject to the
special valuation rules of section 2701 or section 2702, or
if the occurrence of any taxable event described in section
25.2701-4 of this chapter, is not adequately shown on a
return of tax imposed by chapter 12 of subtitle B of the
Internal Revenue Code (without regard to section 2503(b)),
any tax imposed by chapter 12 of subtitle B of the Code on
the transfer or resulting from the taxable event may be
assessed, or a proceeding in court for the collection of the
appropriate tax may be begun without assessment, at any
time.

301.6501(c)-1(e)(2)

Adequately shown. A transfer of property valued under the
rules of section 2701 or section 2702 or any taxable event
described in 25.2701-4 of this chapter will be considered
adequately shown on a return of tax imposed by chapter 12 of
subtitle B of the Internal Revenue Code only if, with
respect to the entire transaction of series of transactions
(including any transaction that affected the transferred
interest) of which the transfer (or taxable event) was a
part, the return provides: etc. etc.

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I am reading a copy of this regulation. After
301.6501(c)-1(e), the next paragraph is numbered (2) and
subsequent numbering seems to imply that the "(2)" means
"301.6501(c)-1(e)(2)".

However, there does not seem to be a paragraph
"301.6501(c)-1(e)(1)". Is this because a paragraph was
deleted when regulation became final?

Sorry to ask what may be an obvious question, but I really
don't understand how this works.

Thanks

<< ================================================== ===== > << The foregoing is intended for educational purposes only > << and does NOT constitute legal OR professional advice. > << > << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org. > << Copyright (2006) - All rights reserved. > << ================================================== ===== >