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the same ratio to the estate tax paid * * * with
respect to the estate of the transferor as the value of
the property transferred bears to the taxable estate of
the transferor (determined for purposes of the estate
tax) * * *
Regulations promulgated under section 2013 specify that if
the interest received by the decedent takes the form of a life
estate, “the value of the interest is determined as of the date
of the transferor’s death on the basis of recognized valuation
principles (see �� 20.2031-7 (or, for certain prior periods, �
20.2031-7A) and 20.7520-1 through 20.7520-4).” Sec. 20.2013-
4(a), Estate Tax Regs.
Section 7520, in turn, states in relevant part:
SEC. 7520. VALUATION TABLES.
(a) General Rule.--For purposes of this title, the
value of any annuity, any interest for life or a term
of years, or any remainder or reversionary interest
shall be determined--
(1) under tables prescribed by the Secretary
* * *
* * * * * * *
(b) Section Not to Apply for Certain Purposes.--
This section shall not apply for purposes of part I of
subchapter D of chapter 1 [relating to deferred
compensation] or any other provision specified in
regulations.
In accordance with the authority granted in section 7520(b)
above, the Commissioner issued section 20.7520-3, Estate Tax
Regs. Paragraph (a) of the regulation begins “Section 7520 of
the Internal Revenue Code does not apply for purposes of” and
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Last modified: May 25, 2011