SECTION 1. PURPOSE

This revenue procedure provides guidance for submitting the information required under § 6501(c)(9) of the Internal Revenue Code and § 301.6501(c)–1(f) of the Procedure and Administration Regulations to adequately disclose a gift if the information was not initially submitted with a gift tax return filed for the calendar year in which the gift was made. The period of limitations on assessment under § 6501(a) will commence to run with respect to such a gift when the taxpayer adequately discloses the gift on an amended gift tax return filed pursuant to this revenue procedure. The period of assessment will generally expire 3 years after the date such amended return is filed.