Internal Revenue Service
Revenue Ruling

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 Rev. Rul. 69-47

1969-1 C.B. 94

Sec. 303

IRS Headnote

A redemption of stock included in a decedent's gross estate, made more than three years and 90 days after the return was filed but within that time period following the due date, meets the requirements of section 303 of the Code.

Full Text

Rev. Rul. 69-47

In a distribution intended to meet the requirements of section 303 of the Internal Revenue Code of 1954, stock included in a decedent's gross estate was redeemed more than three years and 90 days after the date the Federal estate tax return was filed but within three years and 90 days from the date the return was required to be filed. The period of limitation on distributions under section 303 of the Code as provided in section 303(b)(1)(A) of the Code ends 90 days after the expiration of the period of limitation on assessment of the Federal estate tax provided by section 6501(a) of the Code (determined without the application of any provision other than section 6501(a) of the Code).

Held, since the period of limitation provided by section 6501(a) of the Code on the assessment of Federal income tax expires three years after the return was filed and since pursuant to section 6501(b)(1) of the Code, an income tax return filed before the last day prescribed for filing is considered filed on such last day, the distribution meets the requirements of section 303(b)(1)(A) of the Code.