Reduction for consideration. The amount of the transfer (determined under section 2701) is reduced by the amount of consideration in money or money’s worth received by the trans- feror, but not in excess of the amount of the gift (determined without regard to section 2701). The value of consider- ation received by the transferor in the form of an applicable retained interest in the entity is determined under sec- tion 2701 except that, in the case of a contribution to capital, the Step 4 value of such an interest is zero.
Appears in 2 contracts
Sources: Property Division Agreement, Property Conversion Agreement