Final regulations under section 7477 of the Code provide guidance for determining whether a donor may petition the Tax Court for a declaratory judgment with respect to the value of a taxable gift, where the gift does not generate any current gift tax liability.

This notice provides a limited administrative exception to the ability of the Service to examine a Form 706, United States Estate (and Generation-Skipping Transfer) Tax Return, in connection with certain Code section 2053 protective claims for refund filed within the time prescribed in section 6511(a).