§ 2519. Dispositions of certain life estates
(a)
General rule
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)
Property to which this subsection applies
This section applies to any property if a deduction was allowed with respect to the transfer of such property to the donor—