102 STAT. 3752

PUBLIC LAW 100-647—NOV. 10, 1988

26 USC 6512
note.

"(2) there is treated as an administrative expense under
section 2053 either—

"(A) any amount of interest which a decedent's estate
pays on any portion of the tax imposed by section 2001 on
such estate for which the time of payment is extended
under section 6166, or

"(B) interest on any estate, succession, legacy, or inheri-
tance tax imposed by a State on such estate during the
period of the extension of time for payment under section
6166,

then, upon a motion by the petitioner in such case in which such
time for payment of tax has been extended under section 6166, the
Tax Court may reopen the case solely to modify the Court's decision
to reflect such estate's entitlement to a deduction for such adminis-
tration expenses under section 2053 and may hold further trial
solely with respect to the claim for such deduction if, within the
discretion of the Tax Court, such a hearing is deemed necessary. An
order of the Tax Court disposing of a motion under this subsection
shall be reviewable in the same manner as a decision of the Tax
Court, but only with respect to the matters determined in such
order."

(b) CONFORMING AMENDMENTS.—-

(1) Section 6512(a) of the 1986 Code (relating to effect of
petition to Tax Court), as amended by this part, is further
amended by striking out "interest)" and inserting in lieu
thereof "interest or section 7481(d) solely with respect to a
determination of estate tax by the Tax Court)".

(2) Subsection (a) of section 7481 of the 1986 Code, as amended
by this part, is further amended by striking out "subsections (b)
and (c)' and inserting in lieu thereof "subsections (b), (c), and

(d)".

(c) EFFECTIVE DATE.—The amendments made by this section shall
be effective with respect to Tax Court cases for which the decision is
not final on the date of the enactment of this Act.

Subtitle K—Other Administrative Provisions

SEC. 6251. EXCHANGE OF INFORMATION.

Clause (i) of section 6103(b)(5)(B) of the 1986 Code (defining State)
is amended by striking out "2,000,000" and inserting in lieu thereof
"250,000".

SEC. 6252. PROVISIONS RELATING TO PREVIOUSLY REQUIRED STUDIES.

(a) REPEAL OF REQUIREMENT FOR CERTAIN STUDIES.—

(1) PIK STUDY.—Section 6 of the Payment-in-Kind Tax Treat-
26 USC 61 note. ment Act of 1983 is hereby repealed.

(2) ACCOUNTING METHODS FOR INVENTORY.—Section 238 of the
26 USC 471 note. Economic Recovery Tax Act of 1981 is hereby repealed.

(b) CHANGES IN DUE DATES FOR CERTAIN PERIODIC STUDIES.—

26 USC 936 note. (1) REPORTS ON POSSESSIONS CORPORATIONS.—Effective for

reports for calendar years after 1982, subsection (a) of section
441 of the Tax Reform Act of 1984 is amended by striking out
"shall/' and all that follows through "setting forth" and insert-
ing in lieu thereof "shall, during 1988 and each fourth calendar
year thereafter, submit a report to the Congress (using the most
recent information available) setting forth".