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26 USC § 2519 - Dispositions of certain life estates

---
identifier: "/us/usc/t26/s2519"
source: "usc"
legal_status: "official_prima_facie"
title: "26 USC § 2519 - Dispositions of certain life estates"
title_number: 26
title_name: "INTERNAL REVENUE CODE"
section_number: "2519"
section_name: "Dispositions of certain life estates"
chapter_number: 12
chapter_name: "GIFT TAX"
subchapter_number: "B"
subchapter_name: "Transfers"
positive_law: false
currency: "119-84"
last_updated: "2026-04-17"
format_version: "1.1.0"
generator: "[email protected]"
source_credit: "(Added Pub. L. 97–34, title IV, § 403(d)(3)(B)(i), Aug. 13, 1981, 95 Stat. 304; amended Pub. L. 97–448, title I, § 104(a)(3), (7), Jan. 12, 1983, 96 Stat. 2380, 2381.)"
---

# § 2519. Dispositions of certain life estates

**(a)** **General rule** For purposes of this chapter and chapter 11, any disposition of all or part of a qualifying income interest for life in any property to which this section applies shall be treated as a transfer of all interests in such property other than the qualifying income interest.

**(b)** **Property to which this subsection applies** This section applies to any property if a deduction was allowed with respect to the transfer of such property to the donor—

**(1)** under section 2056 by reason of subsection (b)(7) thereof, or

**(2)** under section 2523 by reason of subsection (f) thereof.

**(c)** **Cross reference** For right of recovery for gift tax in the case of property treated as transferred under this section, see section 2207A(b).

---

**Source Credit**: (Added Pub. L. 97–34, title IV, § 403(d)(3)(B)(i), Aug. 13, 1981, 95 Stat. 304; amended Pub. L. 97–448, title I, § 104(a)(3), (7), Jan. 12, 1983, 96 Stat. 2380, 2381.)

## Editorial Notes

### Amendments

1983—, amended directory language of , to clarify that this section be inserted at end of subchapter B of chapter 12, rather than at end of subchapter B of chapter 11, and did not involve any change in text.

Subsec. (a). , substituted “For purposes of this chapter and chapter 11, any disposition” for “Any disposition” and “treated as a transfer of all interests in such property other than the qualifying income interest” for “treated as a transfer of such property”.

Subsec. (c). , added subsec. (c).

## Statutory Notes and Related Subsidiaries

### Effective Date of 1983 Amendment

Amendment by  effective, except as otherwise provided, as if it had been included in the provision of the Economic Recovery Tax Act of 1981, , to which such amendment relates, see , set out as a note under .

### Effective Date

Section applicable to gifts made after , see , set out as an Effective Date of 1981 Amendment note under .