Estate of Edward P. Roski, Sr., Deceased, Edward P. Roski, Jr., Executor - Page 15
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deferred tax plus four years of interest and
must be expected to exist until the entire
tax is paid.
Internal Revenue Manual sec. 18.104.22.168.9(1).
The Commissioner’s determination to require security for all
section 6166 elections was made in response to the recommendation
of the U.S. Treasury Inspector General for Tax Administration
(TIGTA). See TIGTA Rept. 2000-30-059, The Internal Revenue
Service Can Improve the Estate Tax Collection Process (March
2000) (the TIGTA report). The TIGTA report found that 93 percent
of the total outstanding estate tax balances were not secured by
a bond or a special lien for the full term of the agreement. Id.
It also found that the Commissioner was attempting to collect
$177 million in overdue tax balances involving 187 defaulted
installment agreements that had not been secured by bonds or
liens and that $50 million due from 252 estates that had
defaulted on installment agreements not secured by bonds or liens
was no longer collectible. Id. On the basis of these default
rates, the TIGTA report recommended that the Commissioner secure
his interest in all section 6166 deferrals with either bonds or
III. Jurisdiction Under Section 7479
There is a strong presumption that the actions of an
administrative agency are subject to judicial review. Abbott
Labs. v. Gardner, 387 U.S. 136, 140-141 (1967); United States v.
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Last modified: November 10, 2007