Estate of Edward P. Roski, Sr., Deceased, Edward P. Roski, Jr., Executor - Page 5

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               In September 2003, respondent notified the estate that he              
          had received the estate’s notice of election.  Respondent stated            
          that because of the election, the estate was required to either             
          post a bond, or in lieu of a bond, elect to provide a special               
          lien under section 6324A.  By letter dated September 8, 2004, the           
          estate requested that “the government exercise its                          
          Congressionally mandated discretion and not require the posting             
          of a bond or the imposition of a Section 6324A lien in this                 
          case.”  The estate provided the following reasons.3                         
               (1) The estate had explored the possibility of posting a               
          bond but was unable to find a bonding company willing to                    
          underwrite the amount in question for the duration of the 10-year           
          installment payment period under section 6166(a).  Further, even            
          if the estate were able to obtain a bond, the estate’s advisors             
          believed that the cost would be prohibitive.                                
               (2) The assets of the estate are part of a well-established            
          family-owned business, and decedent’s only child has continued              
          the ownership and management of the business.  The estate’s                 
          assets consist of interests in valuable, well-managed, and                  
          profitable active real estate and provide assurance that adequate           

               3There is insufficient evidence in the record to permit the            
          Court to evaluate the merits of the arguments the estate makes in           
          the letter; the letter is reproduced only for purposes of                   
          establishing what information respondent was presented with in              
          order to evaluate the necessity of a bond or a lien.                        

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