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they cannot mutually coexist. Id. at 155. The statutory
provisions here are not so irreconcilable. "[Section] 2040(b)(1)
applies to a qualified joint interest created after 1976, and
* * * [section] 2040(b)(2) redefines a qualified joint interest
for estates of decedents dying after 1981." Gallenstein v.
United States, 975 F.2d at 291; see also Patten v. United States,
supra at 1035 ("[Section 2040(b)(1)] could easily be read to
apply to a qualified joint interest created after December 31,
1976. For decedents dying before January 1, 1982, the old
definition of qualified joint interest applies, while for
decedents dying after December 31, 1981, the current definition
applies.").
2. Later Act Does Not Cover Whole Subject
Moreover, it cannot be said that "the later act covers the
whole subject of the earlier one and is clearly intended as a
substitute". It is clear that this was not a comprehensive
revision of the estate tax treatment of joint interests, designed
to totally displace all prior enactments. Rather, the 1981
amendment merely changed the definition of "qualified joint
interests" contained in section 2040(b)(2) without amending the
operational rule of section 2040(b)(1). The 1981 amendment
cannot stand by itself, as it merely redefines "qualified joint
interests" and is incomplete without the operative inclusion
rules provided in section 2040(a) and (b)(1). Respondent would
have us repeal only the effective date of subsection (b)(1) while
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