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regulation, revenue ruling, or revenue procedure the particular
section for purposes of which section 7520 does not apply. We do
not believe that the relevant language must be read so narrowly,
as it is possible to indicate that valuation tables are
inapplicable for purposes of various Internal Revenue Code
sections in a given set of circumstances by enunciating general
rules, without exhaustively listing such sections by number.
After all, legislative history regarding section 7520 states that
“the provision does not apply to interests valued with respect to
qualified plans or in other situations specified in Treasury
regulations.” H. Conf. Rept. 100-1104 (Vol. II), at 113 (1988),
1988-3 C.B. 603.
Moreover, administrative rulings and case law repeatedly
rejecting taxpayers’ attempts to apply actuarial tables in the
context of common accidents and section 2013 credits existed at
the time section 7520 was enacted. In light of the facially
manifest intent in section 7520(b) that exceptions to the
statute’s application be permitted, we have no basis for
concluding that Congress meant to overrule this administrative
and judicial precedent. We are satisfied that the principles
therein remain valid, and we find the estates’ efforts to avoid
their import through reliance on Estate of McLendon v.
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