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OTHER GIFTS OF REMAINDER INTERESTSenter into a gift and loan agreement pursuant to which they would transferless than their entire interest in any work of art not previously transferredto the charitable organization, provided that the fractional interest transferredwas at least a one-twelfth interest. Although these donors retainedcertain insubstantial rights in the interests that could be transferred (suchas approval rights for the gallery design and the installation design), theydid not retain any ownership reversion rights. If an uncured breach were tooccur, the gifted works would not revert to the donors; the ownershiprights would be transferred to another public charity. The IRS ruled that agift of a fractional interest in any work of the collection accepted by thedonee subject to this gift and loan agreement would qualify as a gift of anundivided portion of the donor’s entire interest in the work. 6666 Priv. Ltr. Rul. 200223013. 514