- 15 - deferred tax plus four years of interest and must be expected to exist until the entire tax is paid. Internal Revenue Manual sec. 4.25.1.4.9(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 special liens. 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.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 NextLast modified: November 10, 2007