US Code

Public Law 119-83 (04/13/2026)

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

If 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 cause

At 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 reference

For 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)72 Stat. 1658 Pub. L. 88–272, title II, § 240(a)78 Stat. 129 Pub. L. 93–625, § 7(d)(1)88 Stat. 2115 Pub. L. 94–455, title XIX, § 1906(b)(13)(A)90 Stat. 1834 (, ; , , ; , , ; , , ; , title XX, § 2004(c)(3), , , 1868.)

Editorial Notes

Amendments

Pub. L. 94–455, § 1906(b)(13)(A)1976—Subsec. (a). , struck out “or his delegate” after “Secretary”.

Pub. L. 94–455, § 2004(c)(3)Subsec. (b). , 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.

Pub. L. 94–455, § 1906(b)(13)(A)Subsec. (c). , struck out “or his delegate” after “Secretary”.

Pub. L. 93–625section 6601(b) of this title1975—Subsec. (c). struck out par. (1) cross reference to interest provisions of and struck out par. (2) designation of cross reference to security, now incorporated in present subsec. (c) provision.

Pub. L. 88–2721964—Subsec. (b). substituted “or periods not in excess of 3” for “not in excess of 2”.

Pub. L. 85–8661958—Subsecs. (b), (c). added subsec. (b) and redesignated former subsec. (b) as (c).

Statutory Notes and Related Subsidiaries

Effective Date of 1976 Amendment

section 2004(c)(3) of Pub. L. 94–455section 2004(g) of Pub. L. 94–455section 6166 of this titleAmendment by applicable to estates of decedents dying after , see , set out as an Effective Date note under .

Effective Date of 1975 Amendment

Pub. L. 93–625section 7(e) of Pub. L. 93–625section 6621 of this titleAmendment by effective on , and applicable to amounts outstanding on such date or arising thereafter, see , set out as an Effective Date note under .

Effective Date of 1964 Amendment

Pub. L. 88–272, title II, § 240(c)78 Stat. 129 Pub. L. 99–514, § 2100 Stat. 2095

“(1)
The amendment made by subsection (a) [amending this section] shall apply in the case of any reversionary or remainder interest only if the time for payment of the tax under chapter 11 of the Internal Revenue Code of 1986 [formerly I.R.C. 1954] attributable to such interest, including any extensions thereof, has not expired on the date of the enactment of this Act [].
“(2)
The amendment made by subsection (b) [amending section 925 of I.R.C. 1939] shall apply in the case of any reversionary or remainder interest only if the time for payment of the tax under chapter 3 of the Internal Revenue Code of 1939 attributable to such interest, including any extensions thereof, has not expired on the date of the enactment of this Act [].”
, , , as amended by , , , provided that:

Effective Date of 1958 Amendment

Pub. L. 85–866, title I, § 66(b)(3)72 Stat. 1658

“The amendments made by paragraphs (1) and (2) [amending this section and sections 925 and 926 of I.R.C. 1939] shall apply in the case of any reversionary or remainder interest only if the precedent interest or interests in the property did not terminate before the beginning of the 6-month period which ends on the date of the enactment of this Act [].”
, , , provided that: