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transferred between victims of a common disaster or to an
individual whose death is clearly imminent. Hence, because the
amount of the credit allowed under section 2013 is proportionate
to the value of the transferred interest, respondent avers that
the estates are entitled to no such credit.
On these facts, we conclude that the spouses’ reciprocal
life estates must be deemed to have a value of zero and,
therefore, will not support allowance of a section 2013 credit.
II. Statutory and Regulatory Provisions
Section 2013 provides a credit against estate tax liability
where the decedent has received property in a transfer from a
person who dies within a prescribed period before or after the
decedent, which transfer is itself subject to estate tax in the
transferor’s estate. The credit is intended “to prevent the
diminution of an estate by the imposition of successive taxes on
the same property within a brief period”. S. Rept. 1622, 83d
Cong., 2d Sess. at 122 (1954). As pertinent herein, the statute
reads:
SEC. 2013. CREDIT FOR TAX ON PRIOR TRANSFERS.
(a) General Rule.--The tax imposed by section 2001
shall be credited with all or a part of the amount of
the Federal estate tax paid with respect to the
transfer of property * * * to the decedent by or from a
person (herein designated as a “transferor”) who died
within 10 years before, or within 2 years after, the
decedent’s death. * * *
(b) Computation of Credit.-- * * * the credit
provided by this section shall be an amount which bears
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