X. Involuntary Gifts
24.A95. Several references have been made in previous paragraphs to the problem of the ‘involuntary donor’—a person who is treated as having made a gift though he has not intended this result. Most often the problem arises in a transaction involving a company; but there may be other occasions, for example in a transaction involving a partnership. The Committee considers that some relief should be given. The donee only should be liable for the tax, and the gift should not be aggregated with other gifts for the purpose of determining the rate of tax on subsequent gifts by the donor.