Cite as: 520 U. S. 93 (1997)
Opinion of Kennedy, J.
ited by its date-of-death value. This is directed by the statutory language capping the deduction at "the value of any interest . . . included in determining the value of the gross estate." It is made explicit by Treas. Reg. § 20.2056(b)-4(a), which says "value, for the purpose of the marital deduction . . . is to be determined as of the date of the decedent's death [unless the estate uses the alternative valuation date]."
Section 20.2056(b)-4(a) provides that "value" for marital deduction purposes is "net value," determined by applying "the same principles . . . as if the amount of a gift to the spouse were being determined." Section 25.2523(a)-1, entitled "Gift to spouse; in general," includes a subsection (e), entitled "Valuation," which parallels § 20.2056(b)-4(d); see also § 20.2055-2(f)(1). Section 25.2523(a)-1(e) provides:
"If the income from property is made payable to the donor or another individual for life or for a term of years, with remainder to the donor's spouse . . . the marital deduction is computed . . . with respect to the present value of the remainder, determined under [26 U. S. C. § ]7520. The present value of the remainder (that is, its value as of the date of gift) is to be determined in accordance with the rules stated in § 25.2512-5 or, for certain prior periods, § 25.2512-5A."
Section 7520, in turn, refers to present-value tables located in regulation § 20.2031-7. The question presented here, involving date-of-death valuation of property or a principal amount, some of the income from which may be used to pay administration expenses, is not controlled by the exact terms of these provisions. For that reason, we do not attempt to force it into their detailed mold. It is natural, however, to apply the present-value principle to the question at hand, as we are directed to do by § 20.2056(b)-4(a). In other words, assuming it were necessary for valuation purposes to take into account that income, see infra, at 106-107 (discussing materiality), this would be done by subtracting from the
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