Section 954. Resident's New York gross estate

(a) General.-- The New York
  gross estate of a deceased resident means his federal  gross  estate  as
  defined  in  the  internal revenue code (whether or not a federal estate
  tax return is required to be filed) modified as follows:
    (1) Reduced by the value of real or tangible personal property  having
  an actual situs outside New York state.
    (2)  Increased  by  the  amount  determined under section nine hundred
  fifty-seven (relating to limited powers of appointment created prior  to
  September first, nineteen hundred thirty).
    (b)  Valuation. -- The New York gross estate shall be valued as of the
  applicable federal valuation date or dates. Any real property  qualified
  under  section  two  thousand  thirty-two-A of the internal revenue code
  shall have the same value for purposes of the New York gross  estate  as
  it has for federal estate tax purposes.
    (c)  Cross  references.--  (1)  For provisions of the internal revenue
  code defining the federal gross estate, see: