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.                                 
               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.            

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