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@macuser_22 wrote:

...Without the 709 the $11 million exemption does not apply and the tax is due.  


@macuser_22 

 

Do you have any authority for the proposition stated (in the above quote)?

 

Treas. Reg. §25.6019-1(f) requires that a gift tax return be filed even if there is no tax due, but I cannot find any authority for the proposition that failing to file a gift tax return serves to eliminate the applicable exclusion amount.