Internal Revenue Service
Revenue Ruling

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 Rev. Rul. 54-30

1954-1 C.B. 207

Full Text

Rev. Rul. 54-30

No part of the lifetime specific exemption allowable under the provisions of section 1004(a)(1) of the Internal Revenue Code to one spouse may be deducted from the value of a gift attributable to the other spouse. The `gift-splitting' provisions of section 1000(f) of the Code do not authorize the filing of a joint gift tax return nor permit the allocation of any portion of the lifetime specific exemption of either spouse to the use of the other. For example, if a husband has no specific exemption remaining available, but his wife does, and the husband makes a gift to which his wife consents pursuant to section 1000(f) of the Code, the specific exemption remaining available may be claimed only on the return of the wife with respect to one-half of the gift. The husband may not claim a specific exemption since he has none available.