Special rule for gifts made after December 31, 1976
(A) In general
(A)In general#
In the case of any gift made after December 31, 1976 , the increase in basis provided by this subsection with respect to any gift for the gift tax paid under chapter 12 shall be an amount (not in excess of the amount of tax so paid) which bears the same ratio to the amount of tax so paid as—
(i) the net appreciation in value of the gift, bears to
(ii) the amount of the gift.
(A)(i)#
the net appreciation in value of the gift, bears to
(A)(ii)#
the amount of the gift.
(B)Net appreciation#
For purposes of paragraph (1), the net appreciation in value of any gift is the amount by which the fair market value of the gift exceeds the donor’s adjusted basis immediately before the gift.