26 U.S.C. § 2623
Taxable amount in case of direct skip
For purposes of this chapter, the taxable amount in the case of a direct skip shall be the value of the property received by the transferee.
(Added Pub. L. 99–514, title XIV, § 1431(a) , Oct. 22, 1986 , 100 Stat. 2721 .)