Estate of Edward P. Roski, Sr., Deceased, Edward P. Roski, Jr., Executor - Page 27

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          with the liquidity problems experienced by estates in which a               
          substantial portion of the assets consist of a closely held                 
          business”.  H. Rept. 94-1380, at 30 (1976), 1976-3 C.B. (Vol. 3)            
          735, 764; and see Estate of Bell v. Commissioner, supra at 902              
          (“The purpose of section 6166 is to prevent the forced                      
          liquidation of closely held businesses because substantial estate           
          taxes must be paid.” (citing H. Rept. 94-1380, supra at 30, 1976-           
          3 C.B. (Vol. 3) at 764, and S. Rept. 94-938 (Part 2), supra at              
          18-19, 1976-3 C.B. (Vol. 3) at 660-661).  Congress was concerned            
          that “In many cases, the executor is forced to sell a decedent’s            
          interest in a farm or other closely held business in order to pay           
          the estate tax.”  H. Rept. 94-1380, supra at 30, 1976-3 C.B.                
          (Vol. 3) at 764.  Allowing the Commissioner to impose a mandatory           
          bond requirement exacerbates the problem that Congress was                  
          dealing with in enacting the statute.  Estates such as the one in           
          this case have liquidity problems that would make it difficult              
          not only to pay tax but also to secure a bond.  Also, the closely           
          held nature of the small businesses that give rise to the                   
          election may make it more difficult for these businesses to be              
          able to offer to secure their assets with liens.  This does not             
          mean, however, that the financial risk is too great to allow the            
          estate to pay its tax in installments.  The record in this case             
          suggests that the executor is a wealthy, well-respected                     
          businessman; that the businesses giving rise to the election are            

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