Estate of Sarah M. Davenport, Deceased, Richard Davenport, Executor - Page 31

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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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