The value of a gift to a spouse effected by the transfer or conversion of his or her spouse's separate property into their community is ordinarily one-half of the total market value of the separate property at the date of the gift.
Note: As to marital exclusion, see Section 15310. As to returning transfers or conversions of separate property into community property, see Section 15656.4.
NOTE: Reference: Section 15551, Revenue and Taxation Code.
Cal. Code Regs. Tit. 18, § 15551.3