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Revenue Procedure 64-19
Internal Revenue Service
1964-1 C.B. 682 (1964)
- Written by Eric Miller, JD
Facts
The Internal Revenue Service received inquiries concerning the treatment of a pecuniary-formula clause directing an executor or trustee of marital assets to use time-of-death valuation rather than time-of-distribution valuation for purposes of the estate tax. The IRS considered the issue in light of the marital deduction for transfers made from one spouse to another upon the death of the first spouse.
Rule of Law
Issue
Holding and Reasoning ()
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