Separate Interests. The Secretary may, by regulation, revenue ruling, notice, or other docu- ment of general application, prescribe rules under which an applicable re- tained interest is treated as two or more separate interests for purposes of section 2701. In addition, the Commis- sioner may, by ruling issued to a tax- payer upon request, treat any applica- ble retained interest as two or more separate interests as may be necessary and appropriate to carry out the pur- poses of section 2701. [T.D. 8395, 57 FR 4264, Feb. 4, 1992] Sections 25.2701–1 through 25.2701–4 and §§ 25.2701–6 and 25.2701–7 are effec- tive as of January 28, 1992. For trans- fers made prior to January 28, 1992, tax- payers may rely on any reasonable in- terpretation of the statutory provi- sions. For these purposes, the provi- sions of the proposed regulations and the final regulations are considered a reasonable interpretation of the statu- tory provisions. [T.D. 8395, 57 FR 4264, Feb. 4, 1992]
Appears in 2 contracts
Sources: Property Division Agreement, Property Conversion Agreement