§ 20.2013-6 — -6 Examples

The application of §§ 20.2013-1 to 20.2013-5 may be further illustrated by the following examples:

(a) A died December 1, 1953, leaving a gross estate of $1,000,000. Expenses, indebtedness, etc., amounted to $90,000. A bequeathed $200,000 to B, his wife, $100,000 of which qualified for the marital deduction. B died November 1, 1954, leaving a gross estate of $500,000. Expenses, indebtedness, etc., amounted to $40,000. B bequeathed $150,000 to charity. A and B were both citizens of the United States. The estates of A and B both paid State death taxes equal to the maximum credit allowable for State death taxes. Death taxes were not a charge on the bequest to B.

(b) “First limitation” on credit for B's estate (§ 20.2013-2):

(c) “Second limitation” on credit for B's estate (§ 20.2013-3):

(1) B's net estate tax payable as described in § 20.2013-3(a)(1) (previously taxed transfer included):

(2) B's net estate tax payable as described in § 20.2013-3(a)(2) (previously taxed transfer excluded):

(3) “Second limitation”:

(d) Credit of B's estate for tax on prior transfers (§ 20.2013-1(c)):

(a) The facts are the same as those contained in example (1) of this paragraph with the following additions. C died December 1, 1950, leaving a gross estate of $250,000. Expenses, indebtedness, etc., amounted to $50,000. C bequeathed $50,000 to B. C was a citizen of the United States. His estate paid State death taxes equal to the maximum credit allowable for State death taxes. Death taxes were not a charge on the bequest to B.

(b) “First limitation” on credit for B's estate (§ 20.2013-2(d))−

(1) With respect to the property received from A:

“First limitation” = $36,393.90 (this computation is identical with the one contained in paragraph (b) of example (1) of this section).

(2) With respect to the property received from C:

(c) “Second limitation” on credit for B's estate (§ 20.2013-3(c)):

(1) B's net estate tax payable as described in § 20.2013-3(a)(1) (previously taxed transfers included) = $61,780.00 (this computation is identical with the one contained in paragraph (c)(1) of example (1) of this section).

(2) B's net estate tax payable as described in § 20.2013-3(a)(2) (previously taxed transfers excluded):

(3) “Second limitation”:

(4) Apportionment of “second limitation” on credit:

(d) Credit of B's estate for tax on prior transfers (§ 20.2013-1(c)):