Section 6166(g)(1)(D) provides:
(g) Acceleration of payment
(D) Subparagraph (A)(i) does not apply to a transfer of property of the decedent to a person entitled by reason of the decedent's death to receive such property under the decedent's will, the applicable law of descent and distribution, or a trust created by the decedent. A similar rule shall apply in the case of a series of subsequent transfers of the property by reason of death so long as each transfer is to a member of the family (within the meaning of section 267(c)(4)) of the transferor in such transfer.
Section 6166(g)(1)(D), Comment 1: This rule applies to transfers of interests in any type of closely held business, not just stock in a corporation. |