disposition
(1) In general Except as provided in paragraphs (2), (3), and (4), for purposes of this part, the term “disposition” includes a sale, exchange, gift, or a transfer of legal title, but does not include— (A) a transfer from a decedent to an estate or a transfer by bequest or inheritance; (B) an exchange to which section 354 , 355 , 356 , or 1036 (or so much of section 1031 as relates to section 1036) applies; or (C) a mere pledge or hypothecation.