The application of §§ 20.2013-1 to 20.2013-5 may be further
illustrated by the following examples:
Example (1).(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):
(d) Credit of B's estate for tax on prior transfers (§
20.2013-1(c)):
Credit for tax on
prior transfers = $18,520.00 (lower of paragraphs (b) and (c)) ×
100 percent (percentage to be taken into account under §
20.2013-1(c))
$18,520.00
Example (2).(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).
(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):
(4) Apportionment of “second limitation” on credit:
Transfer from A (§
20.2013-4)
$100,000.00
Transfer from C (§
20.2013-4)
50,000.00
Total
150,000.00
Portion of “second
limitation” attributable to transfer from A (100/150 of
$27,820.00)
18,546.67
Portion of “second
limitation” attributable to transfer from C (50/150 of
$27,820.00)
9,273.33
(d) Credit of B's estate for tax on prior transfers (§
20.2013-1(c)):
Credit for tax on
transfer from A=
$18,546.67
(lower of “first limitation” computed in paragraph (b)(1) and
“second limitation” apportioned to A's transfer in paragraph
(c)(4)) × 100 percent (percentage to be taken into account under §
20.2013-1(c))
$18,546.67
Credit for tax on
transfer from C=
$9,273.33
(lower of “first limitation” computed in paragraph (b)(2) and
“second limitation” apportioned to B's transfer in paragraph
(c)(4)) × 80 percent (percentage to be taken into account under §
20.2013-1(c))