26 U.S.C. § 2034
Section 2034 · Dower or curtesy interests
Amended 2 times on record
Applied in 11 court decisions — leading case Beaty v. United States (1991)
Most recently applied in United States v. Paulson (September 2018)
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
The value of the gross estate shall include the value of all property to the extent of any interest therein of the surviving spouse, existing at the time of the decedent's death as dower or curtesy, or by virtue of a statute creating an estate in lieu of dower or curtesy.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Amendments
1962—Pub. L. 87–834 struck out provisions which excepted real property situated outside of the United States.
Effective Date of 1962 Amendment
Amendment by Pub. L. 87–834 applicable to estates of decedents dying after Oct. 16, 1962, except as otherwise provided, see section 18(b) of Pub. L. 87–834, set out as a note under section 2031 of this title.