Sec. 25.2701-7 Separate interests.

The Secretary may, by regulation, revenue ruling, notice, or other document of general-application, prescribe rules under which an applicable retained interest is treated as two or more separate interests for purposes of section 2701. In addition, the Commissioner may, by ruling issued to a taxpayer upon request, treat any applicable retained interest as two or more separate interests as may be necessary and appropriate to carry out the purposes of section 2701.

[T.D. 8395, 57 FR 4250-4277, Feb. 4, 1992]