Final Hubert Regulations: The Impact of Administration Expenses on the Charitable Deduction

Final Hubert Regulations: The Impact of Administration Expenses on the Charitable Deduction

Article posted in Regulations on 4 February 2000| comments
audience: National Publication | last updated: 15 September 2012
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Summary

On December 3, 1999, the Treasury issued final regulations regarding how estate administration expenses affect the estate tax marital and charitable deductions. The interrelationships between them are highly complex and, depending on the method of distribution, may require the use of circular computation formulas. In this edition of Planned Giving Online, PGDC Legal Editors review the final regulations and explain how they bring clarity to some previously foggy issues.

By:
Emanuel J. Kallina, II, Esquire
Jonathan D. Ackerman, Esquire
Kathy Hanson, Esquire

Introduction

The charitable bequest is the largest source of planned gifts for U.S. charities. Donors consider a testamentary charitable bequest for philanthropic, personal and tax reasons. The donor may have a history of significant lifetime giving and desires to complete his or her giving on a testamentary basis, or the donor may only want a specific dollar amount bequeathed to his or her heirs, with the balance going to charity. As you know, the donor's estate will be entitled to an estate tax charitable deduction for properly structured charitable bequests.

The issue raised in this article regarding the impact of estate administration expenses on the charitable deduction is highly complex for the uninitiated and very fact specific. This introduction will attempt to simplify and overgeneralize this topic to provide some perspective on the application and impact of this issue. Although this issue is limited in scope, the estate tax charitable deduction, as well as the actual dollar amount distributed to charity (notwithstanding original intentions of the donor), may be affected by the impact of this analysis. These rules impact outright bequests and testamentary planned gifts, such as a charitable remainder trust, charitable lead trust, and pooled income fund.

Prior to the promulgation of the final Regulations, a good deal of confusion surrounded the issue of the impact of the deductibility of estate administration expenses on the charitable, and similarly the marital, deduction. If the spouse's right to income from the property which would ultimately be distributed to such spouse was "materially limited," the marital deduction would be reduced. If the marital deduction is reduced, more estate tax is due. If more estate tax is due, the marital deduction is further reduced, and so on. Because of this circular complication, the IRS requires a circular computation to determine the actual amount of the marital deduction. The same rule applies to the charitable deduction. Thus, the amount actually passing to the surviving spouse or charity, as the case may be, will be reduced. However, the law was unclear as to the definitions of "material limitation" and how the rules worked when administration expenses were paid from income.

For perspective, the time frame in which this issue arises is generally from the date of death of a donor until the final distribution from the donor's estate. During that time period, the personal representative or executor will manage those assets, file income and estate tax returns on behalf of the estate and ultimately make distributions in accordance with the decedent's wishes.

Expenses will be incurred in the process. For instance, if real estate is an asset of the estate, expenses such as taxes, maintenance fees, and utilities may be incurred to manage the property. If a diversified portfolio of stock is owned by the estate, investment advisory fees may be incurred. In fact, these types of expenses would be incurred whether the donor was alive or dead. These fees will be referred to as "estate management fees." The estate will also incur expenses that relate solely to the estate administration process, such as probate fees, the costs of appraisals, personal representative fees, and attorney fees. These fees will be referred to as "estate transmission expenses."

The final Regulations clarify how these different types of estate administration expenses reduce the charitable, or marital, share. The charitable share will generally be reduced by the estate transmission expenses and will not be reduced by the estate management expenses. If the charitable share is reduced, the circular computation discussed above may be required.

An example contained in the Regulations describes the application of these rules to a residuary testamentary bequest to a charitable remainder trust. In the example, a decedent dies in 2000, leaving his residuary estate after the payment of debts, expenses and estate taxes to a charitable remainder unitrust. His estate incurs estate transmission expenses of $400,000 during administration of the estate. The example notes that the residue (i.e., the charitable share) must be reduced by the $400,000 of estate transmission expenses and by the federal and state estate taxes before the present value of the remainder interest in the charitable remainder unitrust can be determined. An interrelated computation will be necessary.

For those readers who desire to learn more about this subject or already have a background in this area, the remainder of this article describes in detail the new Regulations. This article will focus primarily on the charitable deduction provisions, but it should be kept in mind that the marital deduction provisions are essentially the same and will provide guidance in a question regarding the charitable deduction.

Background

It is important to understand how administration expenses may impact the allowable estate tax charitable deduction for purposes of planning testamentary charitable gifts during a donor's lifetime and for purposes of making appropriate post death decisions about the handling of expenses in a donor's estate.

The impact of estate administration expenses on the estate tax charitable deduction has been a subject of debate and controversy for some time. A series of cases distinguished between administration expenses paid from the income generated by property included in an estate and administration expenses paid from the principal of that property for purposes of calculating the charitable and marital deductions.1 After a split among the United States Courts of Appeal, the United States Supreme Court reviewed the issue in Estate of Hubert v. Commissioner.2 In a plurality opinion, the Supreme Court ruled that administration expenses payable from income generated by property reduce the charitable or marital deduction only if the payment constitutes a "marital limitation" on the charity or surviving spouse's right to income from the property pursuant to the then existing Regulations.3 The Supreme Court found that no such material limitation existed in the case at hand and it observed that the Internal Revenue Service ("IRS" or "Service") had not issued any guidance on what constituted a material limitation. As a result of the Supreme Court's holding, the Service announced in 1997 that it was studying the administration expense issue.4

On December 3, 1999, the IRS issued final Regulations under Code 5 Sections 2013, 2055 and 2056 regarding the impact of estate administration expenses on the federal estate tax charitable and marital deductions.6 Corrections to the final Regulations were issued on December 20, 1999.7

Treasury Regulations

In order to fully understand the operation of the new Regulations, some background knowledge about a few Code provisions and some other Regulations may be helpful.

Code Section 2053(a) allows a deduction for estate tax purposes for funeral expenses, administration expenses, claims against an estate and certain mortgages and indebtedness. The amounts must be allowable under the laws of the jurisdiction where the estate is being administered.8 The amount of the deduction for these items may not exceed the value at the date of death of the property subject to claims except to the extent that the deduction is for amounts paid before the time the federal estate tax return is filed.9 Property subject to claims means property included in a decedent's gross estate which would bear the burden for the payment of such deductions under local law reduced by any deduction for losses under Code Section 2054.

Under Code Section 2053(b), a deduction is allowed for the expenses of administering property not subject to claims which is included in a decedent's gross estate to the same extent as if the property had been property subject to claims under Code Section 2053(a) but only to the extent the expenses are paid before the expiration of the period of limitations for assessing estate taxes under Code Section 6501.

In general, administration expenses may be deducted either on the estate's federal estate tax return or its federal income tax return. However, Code Section 642(g) prohibits deducting for income tax purposes an amount deductible for estate tax purposes under Code Section 2053 or 2054 unless the estate files a statement waiving the right to deduct such amounts for federal estate tax purposes.10

Code Section 2055 allows a deduction against the gross estate for certain transfers to qualifying charitable organizations.11 If any death taxes are payable out of the charitable transfer, either pursuant to the will or other governing instrument or under local law, the charitable estate tax deduction must be reduced by the amount of the taxes.12 Prior to amendment in December of 1999, Regulation Section 20.2055-3 contained similar provisions regarding death taxes payable out of charitable gifts. The Regulations noted that an interrelated computation would be necessary to determine the amount of the deduction and the estate taxes.13 As for the impact of administration expenses on the charitable deduction, the rules applicable to the marital deduction were generally looked to in that regard.

Code Section 2056 contains the provisions governing the federal estate tax marital deduction. Code Section 2056(b)(4)(B) indicates that the valuation of any property passing to the surviving spouse must take into account any encumbrances or obligations on that property. Code Section 2056(b)(9) provides, "Nothing in this section or any other provision of this chapter shall allow the value of any interest in property to be deducted under this chapter more than once with respect to the same decedent." The reference to chapter here means all of Chapter 11 of the Code, which encompasses the provisions governing the federal estate tax, including the provisions for the deduction of charitable transfers in Code Section 2055 and the provisions for the deduction of administration expenses in Code Section 2053.

Under the Regulations to Code Section 2056, no marital deduction is allowed for a transfer to a decedent's surviving spouse to the extent that the transfer is allowed as a deduction under Code Section 2053.14 For example, if the surviving spouse received executor's commissions allowed as a deduction under Code Section 2053, those commissions would not be deductible for purposes of Code Section 2056.15

Regulation Section 20.2056(b)-4(c) contains provisions regarding the impact on the marital deduction of the payment of death taxes from a marital transfer which are similar to the provisions found in the Regulations under Code Section 2055 for charitable transfers.

Regulation Section 20.2056(b)-4(a) notes that a marital deduction may be taken "only with respect to the net value of any deductible interest which passed from the decedent to his surviving spouse...." Prior to amendment in December 1999, this Regulation specified:

In determining the value of the interest in property passing to the spouse account must be taken of the effect of any material limitations on the right to income from the property. An example of a case in which this rule may be applied is a bequest of property in trust for the benefit of the decedent's spouse but the income from the property from the date of the decedent's death until distribution of the property to the trustee is to be used to pay expenses incurred in the administration of the estate.16

The Proposed Regulations

After studying the issue of the impact of administration expenses on the marital and charitable deductions and receiving commentary on alternative approaches, the Service issued proposed Regulations in December of 1998.17 The proposed Regulations eliminated the concept of materiality and instead established rules relating to the effect of administration expenses on the valuation of marital and charitable deduction property.18 The IRS noted that the possible tests for materiality would be too complex and difficult to administer.19

The proposed Regulations for the charitable deduction under Code Section 2055 contained a reference to the proposed Regulations for the marital deduction under Code Section 2056 and indicated the rules under proposed Regulation Section 20.2056(b)-4(e) would apply for both marital and charitable deduction purposes.20 The proposed Regulations under Code Section 2056 defined estate transmission expenses and estate management expenses. Estate transmission expenses incurred during the administration of an estate and paid from the principal of property passing to the surviving spouse or income produced by that property would reduce the value of the property for marital deduction purposes.21 Estate transmission expenses were defined as all estate administration expenses that were not management expenses, including such expenses as executor commissions and attorney fees (except those specifically related to investment, preservation, and maintenance of the estate assets), probate fees, appraisal fees and expenses incurred in will construction and will contest defense proceedings.22

Estate management expenses incurred in connection with property passing to a decedent's surviving spouse during the administration of the decedent's estate and paid from the principal of or income produced by that property would not reduce the value of the property for purposes of the marital deduction.23 However, the management expenses would reduce the value of the property passing to the surviving spouse for purposes of the marital deduction if the management expenses were charged to that property but incurred in connection with property passing to some other beneficiary and if a beneficiary other than the surviving spouse was entitled to the income from that property.24 Estate management expenses were defined as expenses incurred in connection with the investment, preservation, and maintenance of estate assets during the period of administration.25 Examples included interest, custodial fees, investment advisory fees, and stock brokerage commissions.26

If the estate management expenses were deducted on the federal estate tax return pursuant to Code Section 2053, the value of the marital deduction property would not be increased as a result of the decrease in federal estate taxes resulting from that Code Section 2053 deduction.27

Several examples of the new rules were included in the Regulations under Code Section 2056.28 The Service requested comments on the proposed Regulations and scheduled a public hearing on April 21, 1999.29

The Final Regulations

As noted above, the final Regulations were issued on December 3, 1999 in Treasury Decision 8846 and corrections to those Regulations were issued in Announcement 2000-3. The Regulations under Code Sections 2055 and 2056 are effective for decedents dying on or after December 3, 1999,30 and the Regulations under Code Section 2013 are effective for transfers from estates of decedents dying on or after December 3, 1999.31 The final Regulations continued the general approach of the proposed Regulations with a few modifications.

In T.D. 8846, the Service discussed some of the comments it received on the proposed Regulations. It noted that several commentators suggested that substantive provisions should be included in the Regulations for the charitable deduction provisions under Code Section 2055. The Service agreed.32 The Service also agreed with suggestions that the distinction between estate transmission and estate management expenses should be more concrete and that examples illustrating the application of the new rules to pecuniary bequests and to estates where no estate taxes are due should be included.33

The IRS noted that many comments were received on proposed Regulation Section 20.2056(b)-4(e)(2)(ii), which stated that the value of the marital deduction would not be increased as a result of the reduced estate taxes caused by deducting estate management expenses under Code Section 2053. As described by the IRS, the commentators fell into two camps.

Some commentators suggested that this provision was not consistent with Code Sections 2056(a) and 2055(c) whereby the value of the charitable or marital deduction is to be reduced only by estate taxes actually paid. These commentators believed the estate should be allowed the full benefit of deducting estate management expenses on the federal estate tax return, including any increase in the marital or charitable deductions that results from the reduction in the estate taxes. Other commentators reached a different conclusion. They believed that an increase in the marital or charitable deduction for the reduction in estate taxes resulting from the deduction of estate management expenses on the federal estate tax return would be inconsistent with Code Section 2056(b)(9), which prohibits deducting the same item more than once for the same decedent under the federal estate tax provisions. After considering the comments, the Service decided to eliminate proposed Regulation Section 20.2056(b)-4(e)(2)(ii) and took a different approach, as described below.

As noted above, the final Regulations include substantive provisions regarding the charitable deduction so those provisions will be described here. Regulation Section 20.2055-3(b) contains definitions of "management expenses," "transmission expenses" and "charitable share."

Management expenses are defined as those "expenses that are incurred in connection with the investment of estate assets or with their preservation or maintenance during a reasonable period of administration." 34Examples cited are interest, custodial fees, investment advisory fees and stock brokerage commissions.35

In response to comments, transmission expenses are defined more concretely in the final Regulations as those "expenses that would not have been incurred but for the decedent's death and the consequent necessity of collecting the decedent's assets, paying the decedent's debts and death taxes, and distributing the decedent's property to those who are entitled to receive it."36 As in the proposed Regulations, transmission expenses also include "any administration expense that is not a management expense."37 The examples are the same as those cited in the proposed Regulations, including executor commissions and attorney fees (except those specifically related to investment, preservation or maintenance of the estate assets), probate fees, appraisal fees and expenses incurred in will construction and will contest defense proceedings.38

A new provision in the final Regulations is the definition of charitable share. The charitable share is defined as "the property or interest in property that passed from the decedent for which a deduction is allowable under section 2055(a) with respect to all or part of the property interest."39 Examples given are bequests to charitable organizations, charitable lead trusts, charitable remainder trusts and pooled income funds.40 The charitable share also includes the income produced by the property during the period of administration if that income, under the terms of the governing instrument or applicable local law, is payable to the charitable organization or is to be added to the principal of the property interest which passes in whole or in part to the charitable organization.41

For purposes of determining the estate tax charitable deduction, the final Regulations provide that the value of the charitable share is to be reduced by the amount of estate transmission expenses paid from the charitable share.42 The charitable share will not be reduced by the amount of estate management expenses attributable to and paid from the charitable share. 43 However, pursuant to Code Section 2056(b)(9), the allowable charitable deduction will be reduced by the amount of any such management expenses that are deducted under Code Section 2053 on the federal estate tax return.44 In addition, the charitable share will also be reduced by the amount of management expenses which are paid from the charitable share and attributable to a property interest not included in the charitable share.45

An example of how these new provisions work was included in the final Regulations.46 In the example, a decedent dies in 2000, leaving his residuary estate after the payment of debts, expenses and estate taxes to a charitable remainder unitrust. His estate incurs estate transmission expenses of $400,000 during administration of the estate. The example notes that the residue (the charitable share) must be reduced by the $400,000 of estate transmission expenses and by the federal and state estate taxes before the present value of the remainder interest in the charitable remainder unitrust can be determined. An interrelated computation will be necessary.47

The final marital deduction provisions found at Regulation Section 20.2056(b)-4(d) are very similar to the final charitable deduction provisions. Seven examples are provided.48 Because similar results would presumably apply for charitable deduction purposes, it is worth reviewing these marital deduction examples here.

In Example 1, a decedent dies after 2006 having made no lifetime gifts. The decedent bequeaths stock having a date of death value of $3 million to his or her child. The child will receive the income from the stock from the date of the decedent's death. The residue, which is valued on the date of death at $6 million before the payment of administration expenses and death taxes, goes to a qualified terminable interest property marital deduction trust. Local law gives the executor the discretion to pay administration expenses from the income or principal of the residue. All death taxes are to be paid from the residue. The state death tax equals the available state death tax credit under Code Section 2011. The estate incurs estate transmission expenses of $400,000 during the period of administration. The executor charges these expenses to the residue.

The example indicates that the value of the residue will be reduced by the death taxes and the estate transmission expenses for purposes of calculating the marital deduction. If the transmission expenses are deducted on the federal estate tax return, the marital deduction will be $3.5 million ($6 million less $400,000 of transmission expenses and $2.1 million of death taxes). Alternatively, if the transmission expenses are deducted on the estate's federal income tax return, the marital deduction will be $3,011,111 ($6 million less $400,000 of transmission expenses and less $2,588,889 of death taxes).49

Example 2 uses the same facts as in Example 1, except that the estate incurs estate management expenses of $400,000 rather than estate transmission expenses. The management expenses are incurred in connection with the residue passing for the benefit of the decedent's spouse. The management expenses are charged to the residue. In determining the value of the residue for marital deduction purposes, a reduction is made for death taxes payable from the residue but no reduction is made for the estate management expenses. Assuming the management expenses are deducted on the estate's federal income tax return, the marital deduction is $3.9 million ($6 million less $2.1 million of death taxes) and the taxable estate is $5.1 million.50

The facts are the same in Example 3, except that the estate management expenses of $400,000 are incurred in connection with the bequest of stock to the decedent's child. The management expenses are charged to the residue. The value of the residue is reduced by the death taxes and the management expenses for purposes of determining the marital deduction. The example notes that the management expenses reduce the value of the residue because they are charged to the property passing to the surviving spouse even though the expenses were incurred with respect to stock passing to the child. If the management expenses are deducted on the estate's federal income tax return, the marital deduction will be $3,011,111 ($6 million less $400,000 of management expenses and less $2,588,889 of death taxes). If the management expenses are deducted on the estate's federal estate tax return, the marital deduction will be $3.5 million ($6 million less $400,000 of management expenses and less $2.1 million of death taxes).51

Example 4 involves a decedent who dies in 2000 with a gross estate of $3 million, which includes proceeds of $150,000 payable to the decedent's child from a policy on the decedent's life. The decedent has no remaining applicable (unified) credit amount. Local law requires the child to pay any estate taxes attributable to the insurance policy. The residue of the estate passes outright to the decedent's surviving spouse under the decedent's will. The estate incurs estate management expenses of $150,000 in connection with the property passing to the spouse during the period of administration. The value of the property passing to the surviving spouse is $2,850,000 ($3 million less the insurance proceeds of $150,000 which go to the child).

For purposes of determining the marital deduction, if the management expenses are deducted on the estate's income tax return, the marital deduction is $2,850,000 ($3 million less $150,000) and the taxable estate is $150,000 ($3 million less the marital deduction of $2,850,000). On the other hand, if the management expenses of $150,000 are deducted on the estate's estate tax return under Code Section 2053, the marital deduction would be limited to $2.7 million and the taxable estate would be $150,000 in accordance with Code Section 2056(b)(9). The example states, "Claiming a marital deduction of $2,850,000 would be taking a deduction for the same $150,000 in property under both sections 2053 and 2056 and would shield from estate taxes the $150,000 in insurance proceeds passing to the decedent's child."52

In Example 5, a decedent dies after 2006 having made no lifetime gifts. The date of death value of the residuary estate is $3 million prior to the payment of administration expenses and death taxes. The residue is divided between two trusts pursuant to a formula in the decedent's will so as to reduce the federal estate taxes to zero. A trust for the decedent's child will be funded with an amount of property equal in value to the available applicable exclusion amount that would reduce the federal estate taxes to zero. The remainder of the property will pass to a qualified terminable interest property marital deduction trust for the benefit of the decedent's surviving spouse. The state estate tax equals the available state death tax credit under Code Section 2011. The estate incurs transmission expenses of $200,000 during administration of the estate.

The transmission expenses of $200,000 reduce the residue to $2.8 million. If the transmission expenses are deducted on the federal estate tax return, then the formula divides the residue so that the value of the property passing to the child's trust is $1 million and the value of the property passing to the marital trust is $1.8 million. The marital deduction is $1.8 million and the applicable exclusion amount shields the $1 million passing to the child's trust from estate taxes. Had the transmission expenses been deducted on the estate's federal income tax return, the formula would divide the residue so that the property passing to the child's trust is $800,000 and the property passing to the marital trust is $2 million. The allowable marital deduction is $2 million and the applicable exclusion amount would shield the amount passing into trust for the child from estate taxes.53

The facts in Example 6 are the same as in Example 5, except that the decedent's will states that the child's trust will be funded with an amount of property equal to the applicable exclusion amount allowable to the decedent's estate. The residue will pass to the marital trust after the payment of any debts, expenses, and death taxes. The child's trust receives $1 million, which is the amount of the applicable exclusion amount. After deducting the $200,000 of transmission expenses, the residue of the estate would be $1.8 million less any estate taxes. If the transmission expenses are deducted on the federal estate tax return, the allowable marital deduction is $1.8 million and no estate taxes are due. However, if the transmission expenses are deducted on the estate's federal income tax return, the net value of the property passing to the surviving spouse would be $1,657,874 ($1.8 million less $142,106 of estate taxes). A marital deduction could be claimed for that amount, which would result in a taxable estate of $1,342,106, with estate taxes totaling $142,106.54

The decedent in Example 7 dies in 2000. His or her will includes an outright pecuniary bequest of $3 million to the surviving spouse. After the payment of all debts, expenses, and death taxes, the residue is to pass to the decedent's child. Under the terms of the will and applicable local law, a beneficiary of a pecuniary bequest is not entitled to any income on the bequest. The estate pays estate transmission expenses during the period of administration from the income earned by the property that will be distributed to the surviving spouse in satisfaction of the pecuniary bequest. Because the income earned on the pecuniary bequest property is not part of the marital share, the allowable marital deduction will be $3 million and it will not be reduced by the estate transmission expenses.55

Treasury Decision 8846 also contains a final Regulation amending the Regulations applicable to the credit for the tax on prior transfers in Code Section 2013. This provision was not part of the proposed Regulations. Essentially, the new Regulation under this Section adds a provision stating that a reduction will be made for administration expenses in accordance with Regulation Section 20.2056(b)-4(d) in calculating the value of property included in a transferror's estate for purposes of determining the value of property transferred to a decedent.56 As noted above, this provision is effective for transfers from estates of decedents dying on or after December 3, 1999. 57

Treasury Decision 8846 indicates that Revenue Rulings 66-233, 58 73-98,59 80-15960 and 93-4861 are all obsolete.


  1. See e.g., Estate of Hubert v. Commissioner, 63 F.3d 1083 (11th Cir. 1995) (involving charitable and marital deductions); Burke v. U.S., 994 F.2d 1576 (Fed. Cir. 1993) (involving charitable deduction); and Estate of Street v. Commissioner, 974 F.2d 723 (6th Cir. 1992) (involving marital deduction).back

  2. 520 U.S. 93, 117 S.Ct. 1124 (1997).back

  3. Id.back

  4. I.R.S. Notice 97-63, 1997-47 I.R.B. 6 (soliciting public comments on possible approaches to the issue for a proposed regulation revising Treas. Reg. § 20.2056(b)-4(a) with respect to the marital deduction).back

  5. All references to the Code are to the Internal Revenue Code of 1986, as amended from time to time.back

  6. T.D. 8846, 1999-51 I.R.B. 679.back

  7. I.R.S. Announcement 2000-3, 2000-2 I.R.B. 296.back

  8. I.R.C. § 2053(a).back

  9. I.R.C. § 2053(c)(2).back

  10. I.R.C. § 642(g).back

  11. I.R.C. § 2055(a).back

  12. I.R.C. § 2055(c).back

  13. See Treas. Reg. § 20.2053-3(b).back

  14. Treas. Reg. § 20.2056(a)-2(b)(2).back

  15. Id.back

  16. Treas. Reg. § 20.2056(b)-4(a).back

  17. REG-114663-97, 1999-6 I.R.B. 17.back

  18. Id.back

  19. Id.back

  20. Prop. Treas. Reg. § 20.2055-1(d)(6).back

  21. Prop. Treas. Reg. § 20.2056(b)-4(e)(1).back

  22. Id.back

  23. Prop. Treas. Reg. § 20.2056(b)-4(e)(2)(i).back

  24. Id.back

  25. Id.back

  26. Id.back

  27. Prop. Treas. Reg. § 20.2056(b)-4(e)(2)(ii).back

  28. See Prop. Treas. Reg. § 20.2056(b)-4(e)(3).back

  29. See REG-114663-97, 1999-6 I.R.B. 17.back

  30. Treas. Reg. § 20.2055-3(b)(7) and Treas. Reg. § 20.2056(b)-4(d)(6) .back

  31. Treas. Reg. § 20.2013-4(b)(3)(ii).back

  32. T.D. 8846, 1999-51 I.R.B. 679.back

  33. Id.back

  34. Treas. Reg. § 20.2055-3(b)(1)(i).back

  35. Id.back

  36. Treas. Reg. § 20.2055-3(b)(1)(ii).back

  37. Id.back

  38. Id. (as corrected by Announcement 2000-3).back

  39. Treas. Reg. § 20.2055-3(b)(1)(iii).back

  40. Id.back

  41. Id.back

  42. Treas. Reg. § 20.2055-3(b)(2).back

  43. Treas. Reg. § 20.2055-3(b)(3).back

  44. Id.back

  45. Treas. Reg. § 20.2055-3(b)(4).back

  46. Treas. Reg. § 20.2055-3(b)(5).back

  47. Id.back

  48. Treas. Reg. § 20.2056(b)-4(d)(5).back

  49. Treas. Reg. § 20.2056(b)-4(d)(5), Example 1.back

  50. Treas. Reg. § 20.2056(b)-4(d)(5), Example 2.back

  51. Treas. Reg. § 20.2056(b)-4(d)(5), Example 3.back

  52. Treas. Reg. § 20.2056(b)-4(d)(5), Example 4.back

  53. Treas. Reg. § 20.2056(b)-4(d)(5), Example 5.back

  54. Treas. Reg. § 20.2056(b)-4(d)(5), Example 6.back

  55. Treas. Reg. § 20.2056(b)-4(d)(5), Example 7.back

  56. Treas. Reg. § 20.2013-4(b)(3)(i).back

  57. Treas. Reg. § 20.2013-4(b)(3)(ii).back

  58. 1966 C.B. 428 (dealing with the credit for tax on prior transfers).back

  59. 1973-1 C.B. 407 (dealing with death taxes payable from charitable transfers).back

  60. 1980-1 C.B. 206 (dealing with the marital deduction and interest on deferred payments of estate taxes).back

  61. 1993-2 C.B. 270 (dealing with the marital and charitable deductions, the credit for tax on prior transfers and interest on deferred payments of estate taxes).back

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