JURISDICTION TO MODIFY DECISIONS IN CERTAIN ESTATE TAX CASES.

SEC. 6247. JURISDICTION TO MODIFY DECISIONS IN CERTAIN ESTATE TAX CASES. (a) In General.—Section 7481 of the 1986 Code (relating to date when Tax Court decision becomes final), as amended by section 783(a), is further amended by adding at the end thereof the following new subsection: “(d) Decisions Relating To Estate Tax Extended Under Section 6166.—If with respect to a decedent’s estate subject to a decision of the Tax Court— “(1) the time for payment of an amount of tax imposed by chapter 11 is extended under section 6166, and 102 STAT. 3752 “(2) there is treated as an administrative expense under section 2053 either— “(A) any amount of interest which a decedent’s estate pays on any portion of the tax imposed by section 2001 on such estate for which the time of payment is extended under section 6166, or “(B) interest on any estate, succession, legacy, or inheritance tax imposed by a State on such estate during the period of the extension of time for payment under section 6166, then, upon a motion by the petitioner in such case in which such time for payment of tax has been extended under section 6166, the Tax Court may reopen the case solely to modify the Court’s decision to reflect such estate’s entitlement to a deduction for such administration expenses under section 2053 and may hold further trial solely with respect to the claim for such deduction if, within the discretion of the Tax Court, such a hearing is deemed necessary. An order of the Tax Court disposing of a motion under this subsection shall be reviewable in the same manner as a decision of the Tax Court, but only with respect to the matters determined in such order.” (b) Conforming Amendments.— (1) Section 6512(a) of the 1986 Code (relating to effect of petition to Tax Court), as amended by this part, is further amended by striking out “interest)” and inserting in lieu thereof “interest or section 7481(d) solely with respect to a determination of estate tax by the Tax Court)”. (2) Subsection (a) of section 7481 of the 1986 Code, as amended by this part, is further amended by striking out “subsections (b) and (c)” and inserting in lieu thereof “subsections (b), (c), and (d)”. (c) Effective Date.—The amendments made by this section shall be effective with respect to Tax Court cases for which the decision is not final on the date of the enactment of this Act.