Extension of Time for Payment of Estate Tax on Reversionary or Remainder Interests

§ 6163. Extension of time for payment of estate tax on value of reversionary or remainder interest in property(a) Extension permittedIf the value of a reversionary or remainder interest in property is included under chapter 11 in the value of the gross estate, the payment of the part of the tax under chapter 11 attributable to such interest may, at the election of the executor, be postponed until 6 months after the termination of the precedent interest or interests in the property, under such regulations as the Secretary may prescribe. (b) Extension for reasonable causeAt the expiration of the period of postponement provided for in subsection (a), the Secretary may, for reasonable cause, extend the time for payment for a reasonable period or periods not in excess of 3 years from the expiration of the period of postponement provided in subsection (a). (c) Cross referenceFor authority of the Secretary to require security in the case of an extension under this section, see section 6165. (Aug. 16, 1954, ch. 736, 68A Stat. 763; Pub. L. 85–866, title I, § 66(b)(1), Sept. 2, 1958, 72 Stat. 1658; Pub. L. 88–272, title II, § 240(a), Feb. 26, 1964, 78 Stat. 129; Pub. L. 93–625, § 7(d)(1), Jan. 3, 1975, 88 Stat. 2115; Pub. L. 94–455, title XIX, § 1906(b)(13)(A), title XX, § 2004(c)(3), Oct. 4, 1976, 90 Stat. 1834, 1868.) Editorial Notes Amendments1976—Subsec. (a). Pub. L. 94–455, § 1906(b)(13)(A), struck out “or his delegate” after “Secretary”. Subsec. (b). Pub. L. 94–455, § 2004(c)(3), substituted provisions relating to extension of time for payment for a reasonable cause for provisions relating to extension of time for payment for undue hardship to the estate. Subsec. (c). Pub. L. 94–455, § 1906(b)(13)(A), struck out “or his delegate” after “Secretary”. 1975—Subsec. (c). Pub. L. 93–625 struck out par. (1) cross reference to interest provisions of section 6601(b) of this title and struck out par. (2) designation of cross reference to security, now incorporated in present subsec. (c) provision. 1964—Subsec. (b). Pub. L. 88–272 substituted “or periods not in excess of 3” for “not in excess of 2”. 1958—Subsecs. (b), (c). Pub. L. 85–866 added subsec. (b) and redesignated former subsec. (b) as (c). Statutory Notes and Related Subsidiaries Effective Date of 1976 AmendmentAmendment by section 2004(c)(3) of Pub. L. 94–455 applicable to estates of decedents dying after Dec. 31, 1976, see section 2004(g) of Pub. L. 94–455, set out as an Effective Date note under section 6166 of this title. Effective Date of 1975 AmendmentAmendment by Pub. L. 93–625 effective on July 1, 1975, and applicable to amounts outstanding on such date or arising thereafter, see section 7(e) of Pub. L. 93–625, set out as an Effective Date note under section 6621 of this title.