- 6 - funds will be available to pay the estate tax liability, therefore mitigating any default risks. (3) Edward P. Roski, Jr., the son of decedent and the executor of the estate, is a highly respected businessman who at all times has fulfilled his tax obligations. (4) The Government already has security for the payment of the estate’s deferred taxes in the form of the statutory lien provided for under section 6324. The lien is in effect until 2010 and is a personal liability of the executor, as well as of all the other transferees of the estate. (5) The imposition of the special lien in lieu of a bond would adversely affect the estate’s ability to carry on the closely held businesses that ultimately are to provide the funds from which the estate’s deferred taxes would be paid. Without the interference of the special lien, the estate will have the cashflow to pay the installments as they become due. (6) The imposition of a special lien, in lieu of a bond, against the estate’s assets would violate covenants in partnership agreements that affect the estate’s interests in those assets and could lead to litigation forcing the estate to sell its properties. Such forced sales would frustrate the purpose of section 6166, which is to avoid forced sales or other actions that might jeopardize the continued operation of a closely held business.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007