128 T.C. No. 10
UNITED STATES TAX COURT
ESTATE OF EDWARD P. ROSKI, SR., DECEASED, EDWARD P. ROSKI, JR.,
EXECUTOR, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5639-05. Filed April 12, 2007.
The estate elected to pay its tax in installments
under sec. 6166(a)(1), I.R.C. (the election). R
informed the estate that it would have to secure a bond
equal to twice the amount of tax deferred or provide a
special lien under sec. 6324A, I.R.C. (special lien),
in order to qualify for the election. R’s requirement
was based on a recent decision by R to make a bond or a
special lien a prerequisite of the election in all
cases. The estate sent R a detailed letter enumerating
reasons why it was impracticable for the estate to
secure a bond or a special lien and requested that R
exercise his discretion and find that it was not
necessary because of the minimal financial risk the
estate’s circumstances posed. R sent the estate a
notice of determination denying the election and
explaining that the estate failed to meet the
requirements for the election because it failed to
provide a bond or a special lien.
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Last modified: November 10, 2007