Where a donor makes gifts of property to each of several persons as part of one transaction under which each donee is to transfer the property received by him to an ultimate donee, the Controller may elect to disregard the severalty of the gifts and compute the tax payable on the aggregate amount transferred as though each gift had been made directly to the ultimate donee. An example of a situation of this kind is where A makes gifts of $4,000 each to B, C, D, and E pursuant to an agreement that they, in turn, will transfer the property given them to G. See also Section 15651 as to returns of gifts to several persons as part of one transaction.

Note: Reference: Section 15211, Revenue and Taxation Code.