The application of §§ 20.2013-1 to 20.2013-5 may be further illustrated by the following examples:
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.
“First limitation” on credit for B's estate (§ 20.2013-2):
“Second limitation” on credit for B's estate (§ 20.2013-3):
B's net estate tax payable as described in § 20.2013-3(a)(1) (previously taxed transfer included):
B's net estate tax payable as described in § 20.2013-3(a)(2) (previously taxed transfer excluded):
“Second limitation”:
Credit of B's estate for tax on prior transfers (§ 20.2013-1(c)):
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.
“First limitation” on credit for B's estate (§ 20.2013-2(d))−
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).
With respect to the property received from C:
“Second limitation” on credit for B's estate (§ 20.2013-3(c)):
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).
B's net estate tax payable as described in § 20.2013-3(a)(2) (previously taxed transfers excluded):
“Second limitation”:
Apportionment of “second limitation” on credit:
Credit of B's estate for tax on prior transfers (§ 20.2013-1(c)):
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