ESTATE TAX IN CASE OF REVERSIONARY OR REMAINDER INTEREST IN PROPERTY.

SEC. 66. ESTATE TAX IN CASE OF REVERSIONARY OR REMAINDER INTEREST IN PROPERTY. (a) Credit for Death Taxes.— (1) Credit under 1954 code.—Section 2015 (relating to credit for death taxes on remainders) is amended by striking out “60 days after the termination of the precedent interest or interests in the property” and inserting in lieu thereof “the time for pay- 72 Stat. 1658 ment of the tax imposed by section 2001 or 2101 as postponed and extended under section 6163”. (2) Credit under 1939 code.—Section 927 of the Internal Revenue Code of 1939 (relating to credit for death taxes) is amended by striking out “60 days after the termination of the precedent interest or interests in the property” and inserting in lieu thereof “the time for payment of the tax imposed by this subchapter as postponed and extended under section 925”. (3) Effective date.—The amendments made by paragraphs (1) and (2) shall apply in the case of any reversionary or remainder interest in property only if the precedent interest or interests in the property did not terminate before the beginning of the 60-day period which ends on the date of the enactment of this Act. (b) Extension of Payment of Estate Tax Attributable to Future Interests.— (1) Extension under 1954 code.—Section 6163 (relating to extension of time for paying estate tax on value of reversionary or remainder interest in property) is amended by redesignating subsection (b) as subsection (c), and by inserting after subsection (a) the following new subsection: (b) Extension To Prevent Undue Hardship.— If the Secretary or his delegate finds that the payment of the tax at the expiration of the period of postponement provided for in subsection (a) would result in undue hardship to the estate, he may extend the time for payment for a reasonable period not in excess of 2 years from the expiration of such period or postponement.” (2) Extension under 1939 code.— (A) Section 925 of the Internal Revenue Code of 1939 (relating to period of extension of time for paying estate tax attributable to future interests) is amended by lidding at the end thereof the following: “If the Secretary or his delegate finds that the payment of the tax at the expiration of the period of postponement provided for in the preceding sentence would result in undue hardship to the estate, he may extend the time for payment for a reasonable period not in excess of 2 years from the expiration of such period of postponement.” (B) Section 926 of the Internal Revenue Code of 1939 (relating to requirements for postponement) is amended by striking out “interest or interests” and inserting in lieu thereof “interest or interests (or, in the case of an extension under section 925, within the period of such extension)”. (3) Effective date.—The amendments made by paragraphs (1) and (2) shall apply in the case of any reversionary or remainder interest only if the precedent interest or interests in the property did not terminate before the beginning of the 6-month period which ends on the date of the enactment of this Act. (c) Interest.—Section 6601 (b) (relating to interest in case of extensions of time for payment of estate taxes) is amended by striking out “if postponement of the payment of an amount of such tax is permitted by section 6163 (a),” and inserting in lieu thereof “if the time for payment of an amount of such tax is postponed or extended as provided by section 6163,”.