Legal Question in Tax Law in New York

The rules are contained in the Income Tax Regulations sec. 25.2511-1(a) and following. There are several examples in the Regulations, but mostly you have to go through the cases and Private Letter Rulings to understand the types of transfers which constitute 'indirect gifts' under sec. 2511 of the Internal Revenue Code. See, for example, Epstein v. Commissioner, 53 T.C. 459 (1969); Clark v. Commissioner, 31 B.T.A. 1082 (1935).

It's a very fact specific analysis.

Hope that helps.

Good luck.