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 Rev. Rul. 54-78

1954-1 C.B. 390

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Rev. Rul. 54-78

The provisions of Article VI(1) of the death duty convention between the United States and the United Kingdom, C. B. 1947-1, 125, insofar as it concerns the limitation period for claiming credit against or refund of Federal estate tax or British estate duty in case of deferment of tax attributable to a reversionary interest, apply only where the estate elects such deferment under such terms and conditions as are prescribed by the statutes of the contracting party involved. (In the United States, secs. 925 and 926 of the Internal Revenue Code. In the United Kingdom, sec. 7(6) of the Finance Act of 1894.)