Estate of Edward P. Roski, Sr., Deceased, Edward P. Roski, Jr., Executor - Page 6

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          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.                                                      

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Last modified: November 10, 2007