SECTION 5. DRAFTING

INFORMATION

The principal author of this revenue procedure is Christina M. Glendening of the Office of Associate Chief Counsel (Income Tax & Accounting). For further information regarding this revenue procedure, contact Ms. Glendening at (202) 622–4920 (not a toll-free call).

gregate value of gifts received in a taxable year exceeds $14,375.

.25 Persons Against Whom a Federal Tax Lien Is Not Valid . For calendar year 2011, a federal tax lien is not valid against (1) certain purchasers under § 6323(b)(4) who purchased personal property in a casual sale for less than $1,400, or (2) a mechanic’s lienor under § 6323(b)(7) that repaired or improved certain residential property if the contract price with the owner is not more than $6,990.

.26 Property Exempt from Levy . For calendar year 2011, the value of property exempt from levy under § 6334(a)(2) (fuel, provisions, furniture, and other household personal effects, as well as arms for personal use, livestock, and poultry) cannot exceed $8,370. The value of property exempt from levy under § 6334(a)(3) (books and tools necessary for the trade, business, or profession of the taxpayer) cannot exceed $4,180.

.27 Interest on a Certain Portion of the Estate Tax Payable in Installments . For an estate of a decedent dying in calendar year 2011, the dollar amount used to determine the “2-percent portion” (for purposes of calculating interest under § 6601(j)) of the estate tax extended as provided in § 6166 is $1,360,000.

.28 Attorney Fee Awards . For fees incurred in calendar year 2011, the attorney fee award limitation under § 7430(c)(1)(B)(iii) is $180 per hour.

.29 Periodic Payments Received un- der Qualified Long-Term Care Insurance Contracts or under Certain Life Insur- ance Contracts . For calendar year 2011, the stated dollar amount of the per diem limitation under § 7702B(d)(4), regarding periodic payments received under a qualified long-term care insurance contract or periodic payments received under a life insurance contract that are treated as paid by reason of the death of a chronically ill individual, is $300.