(C) Rollovers (i) In general Subparagraph (A) shall not apply to that portion of any distribution which, within 60 days of such distribution, is transferred to another qualified down payment savings account for the benefit of the designated beneficiary. (ii) Limitation on certain rollovers Clause (i) shall not apply to any transfer if such transfer occurs within 12 months from the date of a previous transfer to any qualified down payment savings account for the benefit of the designated beneficiary. (4) Estate tax treatment (A) In general No amount shall be includible in the gross estate of any individual for purposes of chapter 11 by reason of an interest in a qualified down payment savings program. (B) Amounts includible in estate of designated beneficiary in certain cases Subparagraph (A) shall not apply to amounts distributed on account of the death of a beneficiary. (C) Amounts includible in estate of donor making excess contributions In the case of a donor who makes the election described in paragraph (2)(B) and who dies before the close of the 5-year period referred to in such paragraph, notwithstanding subparagraph (A), the gross estate of the donor shall include the portion of such contributions properly allocable to periods after the date of death of the donor. (5) Other gift tax rules For purposes of chapters 12 and 13, in no event shall a distribution from a qualified down payment savings account be treated as a taxable gift. (6) Additional tax (A) In general The tax imposed by this chapter for any taxable year on any taxpayer who receives a distribution from a qualified down payment savings program which is includible in gross income shall be increased by 10 percent of the amount which is so includible. (B) Exceptions Subparagraph (A) shall not apply if the payment or distribution is— (i) made to a beneficiary (or to the estate of the designated beneficiary) on or after the death of the designated beneficiary, or (ii) attributable to the designated beneficiary's being disabled (within the meaning of