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However, section 7520, enacted as part of the Technical and
Miscellaneous Revenue Act of 1988, Pub. L. 100-647, sec. 5031(a),
102 Stat. 3668, provides a specific rule for valuing enumerated
forms of property interests, as follows:
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,
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
and deferred compensation] or any other provision
specified in regulations.
For estate tax purposes, regulations promulgated under
section 7520 direct that the relevant actuarial tables for
valuing interests covered by the statute are contained in section
20.2031-7, Estate Tax Regs. Sec. 20.7520-1(a)(1), Estate Tax
Regs.; see also sec. 20.2031-7(d)(5), Example (4), Estate Tax
Regs. (illustrating the calculation for valuing an annuity of
$10,000 per year payable to a decedent or the decedent’s estate).
The regulations under section 7520 also delineate exceptions to
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