Rev. Rul. 75-293

In 1970, A died testate and bequeathed a vested remainder interest in property to B that was included in the gross estate of A for Federal estate tax purposes. At the time of A's death in 1970, the value of B's remainder interest was $50,000 based on the 31/2 percent actuarial tables described in section 20.2031-7 of the Estate Tax Regulations ("Valuation of annuities, life estates, terms for years, remainders, and reversions for estates of decedents dying on or before December 31, 1970"). Based on the 6 percent actuarial tables described in section 20.2031-10 of the regulations applicable to estates of decedents dying after December 31, 1970, the value of B's remainder interest was $35,000. B died in 1974.

Held, for purposes of the credit for tax on prior transfers, if a decedent who died after December 31, 1970, received a remainder interest (or an annuity, life estate, or term for years) from a transferor-decedent who died before January 1, 1971, the interest is valued according to the provisions of section 20.2031-7 of the regulations; thus B's estate is entitled to a credit based on $50,000.

For a ruling containing a similar conclusion with respect to the valuation of an annuity payable under the United States Civil Service Retirement System, see Rev. Rul. 74-557, 1974-2 C.B. 301.