26 U.S.C. § 6163 — Extension of time for payment of estate tax on value of reversionary or remainder interest in property

(a) Extension permitted. Suppose a reversionary or remainder interest in property is counted in a deceased person's gross estate. Then the executor may choose to delay paying the part of the estate tax tied to that interest. Payment can wait until six months after the earlier interest in the property ends, following rules the Secretary sets. (b) Extension for reasonable cause. Once that postponement period runs out, the Secretary may grant more time for a good reason. This further extension can last up to three years past the end of the first postponement. (c) Cross reference. Section 6165 explains the Secretary's power to require security, such as a bond, when granting an extension under this section.

The record The source credit indicates that this section was originally enacted as part of the Internal Revenue Code of 1954, chapter 736, 68A Stat. 763, approved August 16, 1954. It has since been amended four times: by Public Law 85–866 (1958), Public Law 88–272 (1964), Public Law 93–625 (1975), and Public Law 94–455 (1976). The 1976 amendment, part of the Tax Reform Act of 1976, made two separate changes to the section, as reflected in the citations to both title XIX and title XX of that Act. Beyond these dates, titles, and statutory citations, the source credit does not itself explain the substance of each amendment. Historical context The section originates in the 1954 recodification of the Internal Revenue Code, an effort generally understood to have reorganized and modernized federal tax law rather than to have introduced wholly new policy in most provisions. The general purpose of allowing deferred payment of estate tax attributable to reversionary or remainder interests is commonly understood to address the practical difficulty that an estate may owe tax on property interests that will not become possessory, and thus will not generate liquidity, until some future event or the termination of a preceding interest. The record does not establish the specific legislative reasoning behind the subsequent 1958, 1964, 1975, or 1976 amendments, including why Congress adjusted the extension periods or cross-referenced security requirements at those particular times. No further inference should be drawn beyond what the statutory text and source credit state.