Insofar as the asset and liability adjustment concerning an estate (pursuant to the income reported for income tax purposes, with gifts made and notified, and with other adjustments that affect the estate, during the last five (5) years preceding the time of death of the decedent) reveals that such estate has sustained an unjustifiable decrease after a reasonable allowance has been granted to cover subsistence expenses, it shall be presumed that such decrease arises from gifts not reported and the Secretary shall then impose and collect the corresponding taxes thereon as a deficiency, together with the additions to taxes provided under §§ 33001 et seq. of this title in connection with the additions to taxes imposed by this part in cases of fraud. History —Jan. 31, 2011, No. 1, § 2055.04, retroactive to Jan. 1, 2011.