In recent issues of the Digest,1 we have focused attention on the issue of major gifts prompted by perceived tax advantages. The prospect of a new income tax basis at death (and other reasons for not making big gifts during life) have generally trumped the arguments for gifting property during life, at least for heavily appreciated property.2 Another reason to go easy on major gifts during life is that such gifts could affect special use valuation in the donor’s estate if death of the donor occurs less than three years after the date of the gift.3



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