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Secretary may grant an extension, for reasonable cause, up to 10
years from the due date of the return. Interest which arises
because the Secretary permitted a deferred payment of Federal
estate tax under section 6161(a) is deductible from the gross
estate as an administrative expense under section 2053(a)(2).
Estate of Bahr v. Commissioner, 68 T.C. 74, 83 (1977) (Court
reviewed).
1(...continued)
Sec. 6161. EXTENSION OF TIME FOR PAYING TAX.
(a) Amount Determined by Taxpayer on Return.
(1) General rule. The Secretary, except as
otherwise provided in this title, may extend the
time for payment of the amount of the tax shown or
required to be shown, on any return or declaration
required under authority of this title (or any
installment thereof), for a reasonable period not
to exceed 6 months (12 months in the case of
estate tax) from the date fixed for payment
thereof. Such extension may exceed 6 months in
the case of a taxpayer who is abroad.
(2) Estate tax. The Secretary may, for
reasonable cause, extend the time for payment of--
(A) any part of the amount determined by the
executor as the tax imposed by chapter 11, or
(B) any part of any installment under
section 6166 (including any part of a
deficiency prorated to any installment under
such section),
for a reasonable period not in excess of 10 years
from the date prescribed by section 6151(a) for
payment of the tax (or, in the case of an amount
referred to in subparagraph (B), if later, not
beyond the date which is 12 months after the due
date for the last installment).
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Last modified: May 25, 2011