Estate of Paul C. Gribauskas - Page 8




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                         (1) under tables prescribed by the Secretary,                
                    and                                                               
                         (2) by using an interest rate (rounded to the                
                    nearest 2/10ths of 1 percent) equal to 120 percent                
                    of the Federal midterm rate in effect under                       
                    section 1274(d)(1) for the month in which the                     
                    valuation date falls. * * *                                       
                    (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 qualified plans                 
               for deferred compensation] or any other provision                      
               specified in regulations.                                              
               For transfer tax purposes, regulations promulgated under               
          section 7520 provide that the relevant actuarial tables for                 
          valuing interests covered by the statute are contained in section           
          20.2031-7, Estate Tax Regs.  See sec. 20.7520-1(a)(1), Estate Tax           
          Regs.; sec. 25.7520-1(a)(1), Gift Tax Regs.; see also sec.                  
          20.2031-7T(d)(5), Example (4), Temporary Estate Tax Regs., 64               
          Fed. Reg. 23187, 23214 (Apr. 30, 1999) (with effective date May             
          1, 1999, but illustrating the calculation for valuing an annuity            
          of $10,000 per year payable to a decedent or the decedent’s                 
          estate).                                                                    
               The regulations also delineate exceptions to the mandatory             
          use of the tables.  In the estate tax context, paragraph (a) of             
          section 20.7520-3, Estate Tax Regs., lists exceptions effective             
          as of May 1, 1989, while paragraph (b) gives additional                     
          limitations effective with respect to estates of decedents dying            









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