PUBLIC LAW 94-455—OCT. 4, 1976
90 STAT. 1858
" ( i i) the excess of the amount realized w i t h respect to the interest (or, i n any case other than a sale or exchange a t arm's length, the fair market value of the interest) over the value of the interest determined under subsection (a). "(B)
ADJUSTED TAX DIFFERENCE ATTRIBUTABLE TO INTER-
EST.—For purposes of subparagraph (A), the adjusted tax difference attributable to an interest is the amount which bears the same ratio to the adjusted tax difference with respect to the estate (determined under subparagraph (C)) as— " (i) the excess of the value of such interest for purposes of this chapter (determined without regard to subsection (a)) over the value of such interest determined under subsection (a), bears to " (ii) a similar excess determined for all qualified real property. "(C)
"Estate tax liability." Ante, p. 1846.
ADJUSTED TAX DIFFERENCE W I T H RESPECT TO THE
ESTATE.—For purposes of subparagraph (B), the term 'adjusted tax difference w i t h respect to the estate' means the excess of w h a t would have been the estate tax liability b u t for subsection (a) over the estate tax liability. For purposes of this subparagraph, the term 'estate tax liability' means the tax imposed by section 2001 reduced by the credits allowable against such tax. "(D)
PARTIAL DISPOSITIONS.—For purposes of t h i s p a r a -
g r a p h, where the qualified heir disposes of a portion of the interest acquired by (or passing to) such heir (or a predecessor qualified heir) or there is a cessation of use of such a portion— " (i) the value determined under subsection (a) taken into account under subparagraph (A) (ii) with respect to such portion shall be its p r o r a t a share of such value of such interest, and " ( i i) the adjusted tax difference attributable to the interest taken into account with respect to the transaction involving the second or any succeeding portion shall be reduced by the amount of the tax imposed by this subsection w i t h respect to all p r i o r transactions involving portions of such interest. "(3)
P H A S E O U T OF ADDITIONAL TAX BETWEEN lOTH AND 15TH
TEARS.—If the date of the disposition or cessation referred to in paragraph (1) occurs more than 120 months and less than 180 months after the date of the death of the decedent, the amount of the tax imposed by this subsection shall be reduced (but not below zero) by a n amount determined by multiplying the amount of such tax (determined without regard to this paragraph) by a fraction— " (A) the numerator of which is the number of full months after such death in excess of 120, and " (B) the denominator of which is 60. "(4)
O N L Y i ADDITIONAL TAX IMPOSED W I T H RESPECT TO A N T i
PORTION.—In the case of an interest acquired from (or passing from) any decedent, if subparagraph (A) or (B) of paragraph (1) applies to any portion of a n interest, subparagraph (B) or
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