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OPINION
GOEKE, Judge: This matter is before the Court on the
parties’ cross-motions for summary judgment under Rules 121(a)
and 217(b)(2).1
Respondent issued a notice of determination denying the
Estate of Edward P. Roski (the estate) the election to pay
Federal estate tax in installments under section 6166. The
issues before us are: (1) Whether this Court’s jurisdiction
under section 7479 includes reviewing respondent’s determination,
which was based upon his imposition of a security requirement,
that an election may not be made under section 6166; and (2)
whether respondent abused his discretion by imposing a bright-
line requirement of a bond or a special lien for every estate
election under section 6166(a)(1). We hold that we have
jurisdiction under section 7479, and that respondent has abused
his discretion.
The following is a summary of the relevant facts that are
not in dispute. They are stated solely for purposes of deciding
the pending cross-motions for summary judgment and are not
1All Rule references are to the Tax Court Rules of Practice
and Procedure, and all section references are to the Internal
Revenue Code in effect for the date of decedent’s death,
unless otherwise indicated.
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Last modified: November 10, 2007