Estate of Edward P. Roski, Sr., Deceased, Edward P. Roski, Jr., Executor - Page 9

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                    SEC. 6166(a). 5-Year Deferral; 10-Year Installment                
                         (1) In general.--If the value of an                          
                    interest in a closely held business, which is                     
                    included in determining the gross estate of a                     
                    decedent who was (at the date of his death) a                     
                    citizen or resident of the United States                          
                    exceeds 35 percent of the adjusted gross                          
                    estate, the executor may elect to pay part or                     
                    all of the tax imposed by section 2001 in 2                       
                    or more (but not exceeding 10) equal                              
                         (2) Limitation.--The maximum amount of                       
                    tax which may be paid in installments under                       
                    this subsection shall be an amount which                          
                    bears the same ratio to the tax imposed by                        
                    section 2001 (reduced by the credits against                      
                    such tax) as--                                                    
                         (A)  the closely held business                               
                         amount, bears to                                             
                         (B) the amount of the adjusted                               
                         gross estate.                                                
                         (3) Date for payment of                                      
                    installments.--If an election is made under                       
                    paragraph (1), the first installment shall be                     
                    paid on or before the date selected by the                        
                    executor which is not more than 5 years after                     
                    the date prescribed by section 6151(a) for                        
                    payment of the tax, and each succeeding                           
                    installment shall be paid on or before the                        
                    date which is 1 year after the date                               
                    prescribed by this paragraph for payment of                       
                    the preceding installment.                                        
               B.   Bond Requirement                                                  
               Section 6166(d) provides that “If an election under                    
          subsection (a) is made, the provisions of this subtitle shall               
          apply as though the Secretary were extending the time for payment           

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Last modified: November 10, 2007