Estate of Allen v. United States

Kashiwa, Judge,

delivered, the opinion of the court:

This tax refund action involving a question of statutory construction concerning I.R.C. § 2037(b)1 comes before the court after the parties filed an agreed Stipulation of Facts pursuant to Rule 134(b). After briefing and oral argument, we agree with the defendant that the tables of mortality and actuarial principles as provided by the regulations under § 2037 are the exclusive method authorized to value a reversionary interest transfer taking effect at death for federal estate tax purposes. Since those regulations, at present, do not allow…