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of the tax.” Section 6166(k) provides the following cross-
references:
SEC. 6166(k). Cross References–-
(1) Security.--For authority of the
Secretary to require security in the case of
an extension under this section, see section
6165.
(2) Lien.--For special lien (in lieu of
bond) in the case of an extension under this
section, see section 6324A.
Section 6165 provides:
SEC. 6165. BONDS WHERE TIME TO PAY TAX OR DEFICIENCY
HAS BEEN EXTENDED.
In the event the Secretary grants any
extension of time within which to pay any tax
or any deficiency therein, the Secretary may
require the taxpayer to furnish a bond in
such amount (not exceeding double the amount
with respect to which the extension is
granted) conditioned upon the payment of the
amount extended in accordance with the terms
of such extension.
Section 6324A provides in relevant part:
SEC. 6324A. SPECIAL LIEN FOR ESTATE TAX DEFERRED UNDER
SECTION 6166.
(a) General Rule.--In the case of any
estate with respect to which an election has
been made under section 6166, if the executor
makes an election under this section (at such
time and in such manner as the Secretary
shall by regulations prescribe) and files the
agreement referred to in subsection (c), the
deferred amount (plus any interest,
additional amount, addition to tax,
assessable penalty, and costs attributable to
the deferred amount) shall be a lien in favor
of the United States on the section 6166 lien
property.
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Last modified: November 10, 2007