§ 2519. Dispositions of certain life estates

• (a) For purposes of this chapter and chapter 11, any disposition of all or part of a qualifying income interest for life in any property to which this section applies shall be treated as a transfer of all interests in such property other than the qualifying income interest.
• (b) This section applies to any property if a deduction was allowed with respect to the transfer of such property to the donor—
  • (1) under section 2056 by reason of subsection (b)(7) thereof, or
  • (2) under section 2523 by reason of subsection (f) thereof.
• (c) For right of recovery for gift tax in the case of property treated as transferred under this section, see section 2207A(b).