Due to the difficulty of qualifying for the annual exclusion under section 2503, while avoiding the conferral of complete control of the property to an inexperienced minor, Congress passed section 2503(c). However, the efficacy of this section for estate planning was limited by its ambiguity and the Treasury's interpretation. The recent case of Ross v. United States has clarified to a certain extent the meaning of the criteria established by section 2503(c) and has, at least partially, rejected the Treasury's interpretation. In so doing, it has contributed to the usefulness of this section as a workable tool in estate planning.

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