Credit for gift tax.
When more than one gift is included in the gross estate, a separate computation of the two limitations on the credit is to be made for each gift.
The donor made gifts during the calendar year 1955 on which a gift tax was determined as shown below:
Gift of property to son on February 1$13,000Gift of property to wife on May 186,000Gift of property to charitable organization on May 1510,000Total gifts109,000Less exclusions ($3,000 for each gift)9,000Total included amount of gifts100,000Marital deduction (for gift to wife)$43,000Charitable deduction7,000Specific exemption ($30,000 less $20,000 used in prior years)10,000Total deductions60,000Taxable gifts40,000Total gift tax paid for calendar year 19553,600
The donor's gift to his wife was made in contemplation of death and was thereafter included in his gross estate. Under the “first limitation”, the credit with respect to that gift cannot exceed:
[$86,000 − $3,000 − $43,000 (gift to wife, less annual exclusion and marital deduction)] ÷ [$40,000 $10,000 (taxable gifts, plus specific exemption allowed)] × $3,600 (total gift tax paid) = $2,880.