Treasury Regulations, Subchapter B, Sec. 25.2513-4
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Sec. 25.2513-4 Joint and several liability for tax
If consent to the application of the provisions of section 2513 is signified as provided in §25.2513–2, and not revoked as provided in §25.2513–3, the liability with respect to the entire gift tax of each spouse for such “calendar period” (as defined in §25.2502–1(c)(1)) is joint and several. See paragraph (d) of §25.2511–1.
[T.D. 7238, 37 FR 28730, Dec. 29, 1972, as amended by T.D. 7910, 48 FR 40375, Sept. 7, 1983]
