SECTION 1. PURPOSE

This revenue procedure provides procedures for estates of decedents dying before January 1, 1998, to make an election under § 503(d)(2) of the Taxpayer Relief Act of 1997, Pub. L. No. 105–34, 111 Stat. 788 (the “Act”). This § 503(d)(2) election allows an estate to reduce the rate of interest on estate taxes deferred under § 6166 of the Internal Revenue Code and forgo the deduction for interest paid on the deferred estate taxes under §§ 2053 and 163(h).