Should Section 2512(b) be viewed as a part of the definition of gift or as a measuring rod for transfers otherwise identified as gifts? For example, for several months C negotiated with a parents sibling T for the purchase of 100 acres of Ts ranch. T finally sells the property to C for $1,900,000. If the Commissioner asserts, and it cannot be disproved, that the property was worth $2 million:

A) Has T made a gift? See Reg Section 25.2512-8

B) Is Ts intent, donative or otherwise entirely irrelevant?